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The State aid (cash rebate) is a State subsidy for the eligible costs incurred by reimbursing a fixed percentage given after the production of audiovisual works has been completed and if the costs incurred by the investment project have been checked. The rate of aid is 40% of the eligible costs incurred in Greece. The amount of EKOME's state aid is not given in instalments during production or in advance before the start of production, but after production has been completed, as a refund.
(i) Companies founded in Greece operating to produce or offer production services for audiovisual projects (with business activity code 62.01.21)
(ii) Foreign audiovisual production companies with a branch in the Greek territory operating to produce audiovisual projects (with business activity code 62.01.21).
In the case of cross-border productions, applications for cash rebates may be submitted only by producers established or having a branch in the Greek territory.
The application is submitted online to the State Aid Information System at www.ependyseis.gr in the operational environment "Audiovisual Project Investment Incentive". To submit an application, interested parties may consult the application submission handbook for inclusion (request guide).
You can apply to EKOME throughout the year. Applications for State aid for audiovisual works production may be submitted up to 10 days before the start of the production and/or post-production in Greece.
The Operator shall be deemed to be the producer or the Production Service Company who submits the application for inclusion to EKOME via www.ependyseis.gr.
Where the Operator is the Production Service Company, written authorization from the producer, or producers, or co-producers granting them the right to apply for inclusion shall be required.
The beneficiary may be:
a) The domestic producer.
b) The foreign producer.
c) The Investment Plan Operator, subject to written authorization from the producer(s) or co-producer(s) that designates them beneficiaries of State aid from EKOME.
The start of the investment plan is the date when:
a) drafting of the Game Design Document starts;
b) or post-production operations start on Greek territory.
A prerequisite for the approval of the application for inclusion is that development procedures of the Game Design Document start no earlier than 10 calendar days after the application for inclusion.
The end of an investment plan shall be the date set by the Operator as the date of completion of the production and/or post-production of the project.
The costs of the investment plan shall be considered eligible from the date the application is submitted.
Investment plans shall have the right and obligation to be completed within three (3) years from the date the application for inclusion is submitted.
The maximum amount of cash rebate an investment plan can receive is €12 million.
EKOME process of approval of the application for inclusion lasts up to six weeks from the date the application for inclusion is submitted.
The amount of State aid does NOT increase income from business activity, but it is a reducing element of the cost of the expenditure that has been subsidized and is NOT subject to taxation.
A fee of 0.0005 of the total estimated eligible costs is required for the application. This amount shall be a minimum of one hundred and fifty euros (€150) and a maximum of one thousand five hundred euros (€1,500) for the categories (Digital Game, Feature Film/Television Short Film, Animated Film, Documentary Film, TV Documentary Series), and a minimum of two hundred and fifty euros (€250) and a maximum of two thousand five hundred euros (€2,500) for the categories (Feature Film, Television Series, Parts of TV Series Episodes).
In case there is a request for amendment of the inclusion decision, the payment of an additional fee is required, the amount of which is set at 0.0002 of the eligible expenses of the investment plan as defined in the inclusion decision. This amounts to a minimum of two hundred euros (€200) and a maximum of one thousand euros (€1,000), except for the categories (Digital Game, Feature Film/Television Short Film, Animated Film, Documentary Film, TV Series) which amount to a minimum of one hundred euros (€100) and a maximum of one thousand euros (€1,000).
Law No. 4487/2017 specifies the cultural criteria, and their fulfillment is an essential prerequisite for the approval of an application for inclusion or grounds for exclusion if not fulfilled.
The investment plan Operator fills in all cultural criteria categories and proceeds to a reasoned self-scoring for each separate cultural criterion. Following the audit of the application for inclusion, the competent Audit Committee for the Control of Legality and Evaluation of EKOME accepts or changes the cultural criteria score.
The audiovisual works eligible for inclusion are short and feature films, documentaries, television series, animated films.
Audiovisual projects not eligible for inclusion are concerts, recorded performances, sports events and performances, reality shows, recorded events, commercials, infotainment television programs, etc.
Eligible expenses are the ones incurred in the Greek territory which shall not exceed 80% of the total budget of the audiovisual project.
For audiovisual works with eligible expenses over eight million euros (8,000,000 EUR), as far as expenses of par. 1 pertaining to script and directing copyright fees are concerned, or for cultural and educational digital games, as far as expenses for rights to use images - voices, expenses for character design, source code and salaries of crew and cast (except for the fee of the executive producer/production service company) are concerned, it shall be permitted to use invoices issued by natural persons, companies or other legal entities having their registered office or being permanently established in a foreign country. The value of foreign invoices mentioned in the previous point may not exceed 50% of the total eligible expenses involved in the investment plan (VAT excluded).
Pre-production costs incurred, invoiced and paid after the date of application submission shall be eligible.
The minimum threshold for eligible expenses of an investment plan application is €30,000 for digital games.
The maximum threshold of eligible costs of an investment plan application is €30,000,000.
If the final actual costs are lower than those approved, the investment plan shall receive less State aid money from EKOME.
A prerequisite is that at least 60% of the budgeted eligible expenses approved for inclusion, as published in the Government Gazette, must be implemented. If the investment plan has implemented less than 60% of its approved costs, it shall lose any right to receive State aid from EKOME.
Examples include the following:
- Declaration of acceptance of the procedure terms
- Contract between partners (co-production, contract with Production Service Company, etc.)
- Documents related to the operations of the Operator and/or Beneficiary, such as articles of association, balance sheet, certificate of non-bankruptcy, etc.
- Production plan and detailed budget for expenses implemented in Greece
- A definitive financial plan listing all sources of financing with the relevant contracts
- Cultural criteria including a reasoned self-rating.
A full list of all necessary documents to submit is included in Annex 1 of Joint Ministerial Decision 149-2020.
Above the line expenses (copyright for the source code, use of voice or images of famous actors, screenwriting fees, production, music, direction, two leading roles) are eligible up to 35% of the total amount of eligible costs of the audiovisual project.
Please note that the expenses are eligible only when the payment of insurance fees and the relevant taxes in the Greek territory is proven by legal documents.
Wage expenses are eligible only when services are provided in the Greek territory and their tax and social security costs have been paid or legally exempted.
Where production in Greece incurs eligible expenses of more than €8,000,000, eligible foreign production invoices shall be accepted for up to 50% of the total eligible expenses.
|Eligible expenses||Cash Rebate (40% of eligible expenses)||Maximum amount of cash rebate (on eligible expenses invoiced abroad)|
|40,000,000||12,000,000 (legal cap)||6,000,000|
The first example concerns a production where the final implemented total eligible production cost amounts to €5,000,000 (eligible expenses). In this case, the cash rebate could theoretically amount to €2,000,000 (40% of the above total eligible cost). However, for this production, 60% of eligible expenses (value 3,000,000) are invoiced in Greece, and 40% of eligible expenses (value 2,000,000) are invoiced abroad. In this case, the cash rebate is, as it was in the past, limited to a maximum of €1,200,000 (=3,000,000@40%). Eligible expenses invoiced in the rest of the world ( value 2,000,000) cannot be taken into account because the total amount of eligible expenses has not exceeded the minimum amount of 8,000,000 euro (i.e., the minimum amount of eligible expenses specified by the law).
The second example concerns a production where the total cost amounts to 15,000,000 and the final implemented total eligible production cost in Greece amounts to €10,000,000 (eligible expenses). In this case, the cash rebate could amount to €4,000,000 (40% of the above total eligible cost). However, 90% of eligible invoices (worth 9,000,000) are issued in Greece and 10% of the relevant invoices (worth 1,000,000) are issued abroad. In this case, the cash rebate is not affected and (under the conditions defined by the relevant provisions) can amount to 4,000,000.
The third example concerns a production where the total cost amounts to 15,000,000 and the final implemented total eligible production cost in Greece is again €10,000,000 (eligible expenses). In this case, the cash rebate could still amount to a maximum of €4,000,000 (40% of the above total eligible cost). However, in the third example, 10% of the relevant invoices (worth 1,000,000) are issued in Greece and 90% of the relevant invoices (worth 9,000,000) are issued abroad. In this case, the cash rebate is significantly affected. In particular, since in this final implemented total eligible production cost, only €1,000,000 is invoiced in Greece, and the remaining €9,000,000 is invoiced abroad, as far as foreign invoices are concerned, only invoices of €5,000,000 can be taken into account (=50% of total eligible expenses). Therefore, the amount of the aid in question, instead of €4,000,000, would be as follows: (a) 40% of the costs invoiced in Greece (i.e., €400,000), and (b) 40% of €5,000,000 (due to the threshold of 50% of all eligible expenses) invoiced abroad (i.e., €2,000,000). Thus, the total aid for this production cannot exceed €2,400,000 (=400,000+2,000,000).
Travel expenses are eligible for travel to or from Greece, if the relevant fares have been issued by a travel agency liable to the Greek State for the purposes of social welfare and tax contributions which also issues the relevant legal documents. The contributors shall be identified on the production’s list of contributors and on the call sheets.
Eligible expenses are those incurred in the Greek territory and have relevant purchase or rental documents issued by companies based and taxed in Greece.
The expenses for a “pilot” production are not eligible.
Marketing, promotion, and communication expenses, which are costs of promoting rather than producing an audiovisual project, are not included in the total eligible production expenses.
According to EU regulations, the sum of state aid for an audiovisual work in any EU member-state shall not exceed:
Α) 50% of the total budget.
If, for example, the total budget of an investment plan is €1,000,000 and it has already been subsidized by the Greek Film Centre with €200,000, by CNC with €200,000 and by ZDF with €100,000, it has received a total of €500,000 state aid, which equals 50% of the total budget. This production is not eligible for inclusion in the Greek cash rebate because if it receives state aid from EKOME the total amount of state aid will exceed 50% of the total production budget.
Β) in case of a cross-border production, 60% of the total budget (including the state aid by ΕΚΟΜΕ).
Γ) in case of a "difficult" work, 80% of the total budget (including the state aid by ΕΚΟΜΕ).
Cross-border productions are co-productions involving production companies from more than one EU Member States.
"Difficult" is a stand-alone audiovisual project that encounters difficulties in production and promotion and fulfils some or all of the following conditions:
(a) it is entirely in Greek;
(b) it is the first and/or second project of a director or the first and/or second project of a producer;
c) it has a budget of up to €500,000.
There is a specific category in the cultural criteria (JMD 149/2020, Appendix 3, Table E) which determines when an audiovisual project may be defined as "difficult" by reasoned self-rating by the Operator, which is then assessed by EKOME’s Committee for the Control of Legality and Evaluation.
A newly founded production company may apply for aid with an obligation to submit financial data for the period it has been set up. Companies under incorporation and consortia are also entitled to apply for aid under the conditions laid down in Article 3 of Law 4704/2020.
The maximum remuneration for the production service company has been set at 10% of the total budget that the company has undertaken to implement, which may be demonstrated through a contract with the main production company/companies.
Expenses included in the budget of a project do NOT include Value Added Tax, apart from those that pertain to fuel, accommodation, and meals, which are calculated with the applicable VAT.
The Operator may request an amendment of the approved eligible budget by filling a request for amendment at www.ependyseis.gr before the expiration date of its investment plan.
Such requests shall be admissible provided that the general and legal conditions for inclusion continue to be valid. The request shall be accompanied by a technical description justifying its feasibility. Upon receipt of the request, a review of the cultural criteria score of the approved investment plan is required before the request can be approved or not.
The budget categories may be amended, provided that the amount of the investment plan’s total budget does not change and the request for amendment is made before the expiration of the investment plan.
You may submit a request for audit within a period of no more than six (6) months from the date your investment plan has been completed. You will have to file your request at www.ependyseis.gr, accompanied by the necessary supporting documents, and the report of the Certified Accountant you hire and pay. The Certified Accountant’s Report should follow the standard set out in JMD 7651/2021 (Government Gazette B/1086).
You should submit the electronic application for audit to the State Aid Information System (SAIS) (www.ependyseis.gr) with supporting documents in digital format. You shall send a hard copy to EKOME, within 3 days of filing the application with the State Aid Information System (SAIS), accompanied with copies of expenses receipts and their supporting documents (as described in the Aid Request Guide).
As regards the attachments sent to the State Aid Information System (SAIS), the following limitations apply:
- Maximum size of each attached file: 10MB
- Total maximum size of attachments per operation: 50MB
- Acceptable file types: .gif, .zip, .rar
This table shall be submitted in Excel format, both in hard copy and digital copy, together with the remaining supporting documents. A template can be found at www.ependyseis.gr.
There is no extension to the Audit Request submission. However, if the investment plan has not expired, the Operator may request an amendment for the extension of the investment plan’s expiration date, postponing it to a later date.
You are advised to avoid finalizing the digital Audit Request before you have resolved all your financial questions! The Audit Guide takes you step by step through the process.
For any technical questions or difficulties when filing the Review Request digitally via the State Aid Information System (SAIS), please contact: email@example.com.
For more general financial questions regarding the Audit Request, please forward your queries to: firstname.lastname@example.org. The investment plan management team will provide direct guidance.
To assist investment operators, EKOME developed and uploaded at www.ependyseis.gr (Information) a State Aid Request Submission Guide, which clarifies the number and type of supporting documents necessary to file a Audit Request. Please note that filing of the request consists of two stages: (A) firstly, the electronic application is submitted at www.ependyseis.gr with the supporting documents in electronic format; (B) a hard copy with copies of the supporting documents and the necessary accompanying documents is submitted to EKOME (as described in the State Aid Request Submission Guide), along with the Certified Auditor's Report, in accordance with the standard specified in the corresponding JMD 7651/2021 (Government Gazette B/1086).
At the audit stage, you shall identify any deviations/amendments with respect to the technical description of the investment plan already approved by the relevant application for the date aid. In other words, you may use your original text, adding the final variations with justification and concluding with the final implemented investment plan. If at some point, e.g., in (b) (scenario) no changes have been made, indicate that there has been no change to the original plan.
No, your request will not be rejected due to omissions, as these are identified and recorded in the course of the audit process, as described in the relevant case law. The Audit Committee shall examine the supporting documents filed, and send an e-mail detailing the missing supporting documents to the investment plan Operator. The Operator shall have twelve (12) calendar days from the date this message is received to collect and send the missing supporting documents to EKOME.
Examples of the hard copy documentation are:
a) Report by the Certified Auditor in accordance with the standard specified in the corresponding JMD 1086/22.03.2021;
(b) copies of the supporting documents for all eligible expenses, stamped with the application form’s unique number, clearly photocopied from the originals, with an equally clear proof of payment attached;
(c) a list of supporting documents requested by the Operator and their settlement (see standard file "BUDGET AND REPORTING TABLE TEMPLATE" in the Aid Request Guide). To facilitate the audit, this table should also be included in the electronic files the entity uploads to the State Aid Information System (SAIS) during the audit request stage;
(d) supplier account statements (records);
(e) the Operator’s current account statement;
(f) the USB 3.0 hard disk with the audiovisual material supporting the fulfilment of the cultural criteria;
g) If the operator has regular staff working for the investment plan in question, the hard copy shall include detailed timesheets of the hours spent on the investment plan (in relation to the total hours worked).
To speed up audits, the documents in the hard copy file should be classified following the logic of Annex 2 of JMD 7651/2021 (Government Gazette B1086/22.03.2021), which divides eligible expenditure into seven distinct categories (copyright expenses, crew fees, etc.) and the Budget and Financial Statements Table.
The final USB 3.0 deliverable shall include material which substantiates that the cultural criteria have been met, and which allows for the investment plan to benefit from an aid scheme. A review of the credit points for the fulfilment of the cultural criteria is advisable, highlighting any deviations from the application for inclusion. The hard disk shall contain photographs from the production process, local press reports about the production, making-offs, opening and/or end credits with EKOME’s logo, etc.
If the beneficiary is a production company with a Greek Tax ID number, it may obtain a short-term loan from a domestic bank equal to the assigned aid, which will be used to implement the investment plan. In this case, the aid shall be paid directly to the bank with which the contract of assignment of the claim is signed.
Once the completion decision has been issued, you will be asked to provide specific documents to the Financing Programs and Development Department of EKOME, so that, following the audit, the aid will be remitted by bank transfer to the beneficiary's IBAN.