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If fewer or more expenses than those approved are implemented, is it possible to request an amendment of the eligible budget?

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.

Should the VAT be included in the budget for an audiovisual project?

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.

Is there a cap on the fee of the executive production company?

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.

Can a newly established production company apply for the Greek cash rebate?

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.

What is a “difficult” audiovisual work?

“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.

What is a cross-border production?

Cross-border productions are co-productions involving production companies from more than one EU Member States.

Is there a limit to the state aid amount relating to the overall budget of the audiovisual work?

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).

Are marketing, promotion and communication expenses included in the total eligible production costs?

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.

Are eligible the expenses for a “pilot” production?

The expenses for a “pilot” production are not eligible.

Are the costs spent on imported vehicles and equipment eligible?

Eligible expenses are those incurred in the Greek territory and have relevant purchase or rental documents issued by companies based and taxed in Greece.

Are travel expenses eligible for the transportation of cast and crew to and from Greece?

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. 

Are the expenses for foreign cast and crew eligible?

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)
5,000,000 2,000,000  0
8,000,000 3,200,000 1,600,000
20,000,000 8,000,000 4,000,000
30,000,000 12,000,000 6,000,000
40,000,000 12,000,000 (legal cap) 6,000,000

 

Example 1

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).

Example 2

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.

Example 3

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).

 

Are there any restrictions on the amount of above the line expenses that are considered eligible?

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.

What kind of documents do I need to submit with my application?

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.

If the final eligible costs incurred are less than the approved budget, how is the aid calculated?

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.

Is there a minimum or maximum amount of eligible expenses?

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.

 

Are expenses incurred during pre-production phase considered as eligible?

Pre-production costs incurred, invoiced and paid after the date of application submission shall be eligible.

What does the term “eligible expenses” mean and how are they defined?

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).

Which audiovisual works are eligible for the investment scheme and which ones are excluded?

The audiovisual works eligible for inclusion are short and feature films, documentaries, television series, animated films and digital games.

Audiovisual projects not eligible for inclusion are concerts, recorded performances, sports events and performances, reality shows, recorded events, commercials, infotainment television programs, etc.

How are cultural criteria determined?

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.

What is the cost of application submission?

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).

How long does it take for an investment plan to be approved?

EKOME process of approval of the application for inclusion lasts up to six weeks from the date the application for inclusion is submitted.

Is there a cap on the amount of state aid managed by EKOME?

The maximum amount of cash rebate an investment plan can receive is €12 million.

From what date on wards can expenses count as eligible?

The costs of the investment plan shall be considered eligible from the date the application is submitted.

Who is the beneficiary of the state aid managed by EKOME?

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.

Who is the Investment Plan Operator?

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.

When shall I apply for the Greek cash rebate?

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.

Who can apply for the Greek cash rebate?

(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.

How can I apply for the Greek cash rebate?

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).