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The investment incentive (cash rebate) is a state subsidy given after the completion of the production of audiovisual works, when the costs of the investment plan have been audited. The rebate amounts to 40% of the eligible costs incurred in Greece.
It is underlined that the amount of the state aid implemented by EKOME is not allotted in part during the production, nor in advance before the start of the production, but after the production has been completed.
(i) Companies founded in Greece operating to produce or offer production services for audiovisual projects (with business activity codes 59.11 or 59.12 or 62.01.21)
(ii) Foreign audiovisual production companies with a branch in the Greek territory operating to produce audiovisual projects (with business activity codes 59.11 or 59.12 or 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) either filming of an audiovisual project on Greek territory starts/drafting of the Game Design Document (for digital games) starts/the animation procedures start (for animated films);
b) or the contract for the leasing of technical equipment for the execution of scheduled filming on Greek territory goes into effect;
c) or post-production operations start on Greek territory.
A prerequisite for the approval of the application for inclusion is that filming/ development procedures of the Game Design Document (for digital games) /animated film procedures 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 State aid (cash rebate) is disbursed by EKOME once the production of audiovisual projects has been completed and the costs of the investment plan have been audited. The rebate amounts to 40% of the eligible expenses implemented in Greece. The amount of State aid from EKOME shall not be paid in instalments during production, nor in advance at the start of the production, but once production has been completed, as a rebate.
The costs of the investment plan shall be considered eligible from the date the application is submitted.
“Expenses pertaining to script and directing copyright fees” pursuant to Law 4487/2017, as amended and in force, in conjunction with the new JMD 1086/2021, are expenses defined in Law 2121/1993, as amended and in force. More specifically, they concern compensation for projects leading to a specific permit with a specific range of powers from the principal creator (director), and the key creator of individual contributions (scriptwriter). The remuneration shall be determined by a contract between the producer and the director or writer. These expenses shall not include any form of remuneration based on revenues or expenses incurred from the commercial exploitation of the project, which are not related to its production. As regards the eligibility of costs of directors and scriptwriters incurred abroad, the contract between the producer and the director or scriptwriter shall explicitly mention the Greek territory as the place where the project is executed in its entirety. If there are multiple filming sites, separate contracts shall have to be concluded for Greece, so that all compensations related to Greece are eligible, pursuant to the provisions of the Law and the JMD. Moreover, for all the above cases, apart from the fact that the project in question must be executed entirely on Greek territory, invoicing and payment for this cost shall be implemented after the submission date of the relevant application for inclusion of the audiovisual project pursuant to the provisions of Law 4487/2017.
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.
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 and 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).
Eligible for inclusion are the following:
(a) production phase,
(b) production and post-production phase,
(c) or post-production phase
of the investment plan implementation.
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 €100,000 for cinema or TV fiction films, €60,000 for TV or cinema documentaries, or short fiction films, or animated films, and €30,000 for digital games. For TV series and episode parts, the minimum threshold is set from €15,000 (at least 70 episodes) to €25,000 per episode (€20,000 for TV docuseries), and the total budget of all episodes not less than €100,000 (€60,00 for TV docuseries).
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
- The complete scenario or scenario summary of the audiovisual project or concept design document
A full list of all necessary documents to submit is included in Annex 1 of Joint Ministerial Decision 149-2020.
The total wages of the main ATL contributors (copyrights, script, production, music, direction, two leading roles) are eligible up to 35% of the audiovisual project’s eligible costs.
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).
They are eligible for travel to or from Greece, and 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 incurred for the production of a pilot by an investment plan included in the cash rebate program do not constitute eligible expenses.
Marketing, promotion, and publicity expenses, which are costs for 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 project in any EU Member State must not exceed 50% of its total budget. For cross-border productions, the maximum aid may amount to 60% of their total budget (including EKOME State aid) and for "difficult" audiovisual projects, 80% of their total budget (including EKOME State aid).
If, for example, the total budget of an investment plan with one producer is €1,000,000 and it has already been financed by the Greek Film Centre for €200,000, the CNC for €200,000, and ZDF for €100,000, meaning it has received a total of €500,000 of State aid amounting to 50% of its total budget, this production cannot be eligible for inclusion in EKOME because by receiving State aid from EKOME, it would exceed the percentage of 50% of total State aid in its total budget.
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.
There is no limit on filming days.
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 filing 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.
If the filming locations and dates change, but the physical scope of the investment plan does not change, the Operator shall inform EKOME of the change in the implementation of the investment plan without filing a request for amendment.
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 firstname.lastname@example.org.
For more general financial questions regarding the Audit Request, please forward your queries to: email@example.com. 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 filming, 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.
The two incentives are complementary but you need to apply for each one separately.
The eligible costs in the Tax Relief are the same as the eligible costs in the Cash Rebate. They may not exceed 80% of the total costs. They must not breach the conditions set by Law 4487/2017, as amended and in force, regarding the minimum amount of costs submitted for approval of the audiovisual works. In the tax relief, the audiovisual work must obligatorily be managed the financially through a Special Bank Account in order for the costs to be considered as eligible.
The application is submitted on the website of EKOME to the State Aid Information System (PSKE) either by acquiring the passwords of a new user or by updating the passwords of an old user.
The qualification application must be accompanied by the following supporting documents:
i. An application form on paper, filled in and signed by the producer or the legal representative of the applicant company.
ii. A tax and social security clearance certificate for the applying natural person, or the production company according to its articles of association.
iii. Detailed budget of the audiovisual work and a list of main cast and crew.
iv. Production schedule, production locations and production labs.
v. Detailed financial plan including the funding sources and accompanied by all evidence of its coverage (co-production agreements, decisions of public or international organizations, etc.)
vi. Intellectual property acquisition agreement.
vii. A co-production agreement.
viii. Contracts between the production company and the production service company.
ix. An Internal Revenue Service (DOY) certificate on the business activities of the company.
xi. An administrative fee of €100.
All legal documents for the eligible costs are issued in the name of the producer of the work or in the name of the executive producer. In the case of co-production, the documents of the eligible costs are issued by each producer separately, according to their participation in the production on the basis of the co-production agreement submitted to EKOME for the specific audiovisual work.
Amounts paid by legal entities as well as natural persons engaged in business activity and concern thirty percent (30%) of the eligible costs of each audiovisual work, are deducted from their net taxable results, as they result from the income tax return of the tax year to which they relate.
For natural persons not engaged in business activity, thirty percent (30%) of the eligible costs are deducted from their taxable income in proportion to their income category.
Tax relief is calculated on the basis of the financial plan submitted by the producer and such calculation states the percentages of the financiers of the Investment Plan that agree with the submitted agreements between the financiers and the Producer.
In the case of co-productions, the amount deducted is calculated according to the participation of the natural or legal person or legal entity in the production.
Tax relief is linked to the incurred eligible costs which do not need to be incurred within the same fiscal period.
EKOME, after checking the supporting documents and supporting documents of the eligible costs, certifies their eligibility for the specific audiovisual work, as well as that the percentage of deduction of expenses from taxable income, together with other aid received by the natural or legal person or legal entity for the same audiovisual work, may not exceed 50% of the production costs of that work. For cross-border productions the limit on the production costs of this work is increased to 60% and for "difficult" projects to 80%.
Only the amount of the tax relief corresponding to the producer and not to the private financiers is calculated in the cumulation.
In case losses occur after the deduction of the above costs, such loss is transferred under the provisions of article 27 of Law 4172/2013.
If within 36 months from the submission of the application for qualification of the audiovisual work for the tax relief, the work cannot be completed due to failure of the producer and failure for a new producer to be found, the relevant document must be communicated to the competent Tax Office (D.O.Y.) within one month of non-completion of the work and the amounts paid deducted from the net taxable results are added to the income tax return of the tax year when the above document was communicated according to the above.