Co-productions: attribution of expenditure between co-producers
S1216AH, S1216CL Corporation Tax Act 2009
A Television Production Company’s (TPC’s) entitlement to Television Tax Relief (TTR) is based on the amount of core expenditure that it incurs (TPC50005).
Where a TPC is involved in a co-production it would be expected that the arrangements between the co-producers were such that each co-producer bore the expenditure for which they were ultimately responsible. It would also be expected that the accounts of the TPC’s separate deemed trade (TPC20010) reflected that same division of responsibility.
HMRC can be expected to critically test expenditure where the arrangements between the co-producers are such that:
- accounts of the TPC’s trade include expenditure that is ultimately attributable to another co-producer, but
- was incurred by the TPC.
The expenditure should be:
- excluded from the costs of the programme because it is not incurred wholly and exclusively for the purpose of the TPC’s separate trade (TPC20230), and/or
- disregarded for the purposes of determining the amount of any additional deduction or payable credit because the arrangements have been structured in such way so as to increase the TPC’s entitlement to the deduction or credit (TPC80050).