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UK Tax Credit with Production Abroad

UK Tax Credit with Production Abroad. May 2011 RSM Tenon Media 66 Chiltern Street London W1U 4JT Tel: + 44 207 535 1400 Fax + 44 207 535 1401. Why is UK so popular?. Reliability & value of incentive - ATL Favourable exchange rate - CAN/AUS/EU

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UK Tax Credit with Production Abroad

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  1. UK Tax Credit with Production Abroad May 2011 RSM Tenon Media 66 Chiltern Street London W1U 4JT Tel: + 44 207 535 1400 Fax + 44 207 535 1401

  2. Why is UK so popular? • Reliability & value of incentive • - ATL • Favourable exchange rate • - CAN/AUS/EU • Excellent technicians/talent/craftsmen/facilities • An excellent Film Commission & Certification Team • BUT • Cost creep • Exchange rate

  3. Structure • Coproduction v Culture Test • - other incentives e.g. CAN/AUS/NZ/SA • - ability to pass the Culture Test • - may need more points in A & B • - more flexible than it first appears • FPC requirement • - get structure right early

  4. Minimum & Maximum Spend • 25% minimum - consider what counts • - post/VFX/music • - director, writer, producer, script, insurance • - IATSE • 80% maximum - no penalty • Nationality blind • Used or consumed • - apportionments • - time v cost

  5. Which Territory? • Things to consider • Script (e.g. Louisiana, New York) • Asymmetry • Timing • Real value • - headline v base • - transaction costs • Non core & double dip • e.g. rights/writers/bond/finance/insurance

  6. Foreign Exchange • Match finance & expenditure • Translation for UK tax credit • Use of budgeted rate

  7. Conclusion • Choose structure and get it right up front • Consider foreign exchange exposure, commercially & vis a vis tax credit • Choose state/province carefully (& local producer!) • Maximise incentives • Personal tax • What is real value

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