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What is the investment incentive (cash rebate) that is implemented by EKOME?

The investment incentive (cash rebate) is a state aid 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.

 

Who is eligible for the Greek cash rebate?

i) Undertakings that are established in the Greek territory and operate to produce audiovisual works (Business Activity Code 59.11 and 59.12)

ii) Foreign audiovisual production companies that have a branch on Greek territory (Business Activity Code 59.11 and 59.12)

In case of cross-border productions, eligible to apply for the cash rebate are only Greek production companies or production service companies.

How can I apply for the Greek cash rebate?

Application may be submitted online either through our website, or directly to the Information System for State Aid on www.ependyseis.gr. After signing up on the “Investment Incentive of Audiovisual Works” platform, the user may consult the manual for application submission (User Manual). For the application submission, users need to register to the platform www.ependyseis.gr.

When shall I apply for the Greek cash rebate?

You may apply to EKOME all year long. Applications for state aid for audiovisual work production should be submitted at least 10 days before the beginning of the works (principal photography or post-production) in the Greek territory. 

Who is the implementing body of the investment incentive plan?

Implementing body of the investment incentive plan is the producer or executive producer that submits an application to EKOME through the www.ependyseis.gr platform.

In case of the executive producer, a written authorization is required from the producer(s) or co-producers granting them the right to submit the application.  

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

The beneficiary may be one of the following:

a) The Greek production company (whether the application is submitted by them or and production service company)

b) The foreign production company, provided they keep a branch in Greek territory (Business Activity Code 59.11 and 59.12) and a Greek IBAN

c) The implementing body of the investment provided it has a written authorization from the Producer or the Producers or the Co-Producers appointed by the beneficiary to receive the state aid from EKOME.

What do the terms “onset” and “completion” of an "investment plan" stand for?

The onset of the investment plan is defined as the first point in time that either:

a) filming of an audiovisual work in the Greek territory begins, or:

b) the first legally binding undertaking for the lease of equipment for the purpose of implementing a planned shooting in the Greek territory.

Completion of an investment plan is considered the completion of  filming and/or post-production of the project.

Necessary condition for the approval of the inclusion proposal is that the shooting starts 60 calendar days after the application has been submitted.

From what date on wards can expenses count as eligible? The date of application submission or the starting date of the investment plan?

Eligible are the expenses incurred from the date of application submission onward.

Is there a time limit for the conclusion of an investment plan?

Investment plans have the right and the obligation to conclude within three (3) years from the date of application submission for the cash rebate.

Is there a cap on the amount of state aid managed by EKOME and the maximum total eligible budget that an investment plan can apply for?

Law 4563/2018 does not have a cap on the amount of aid, nor a ceiling on the budget for eligible expenses.

How long does it take to get an investment plan approved?

The procedure for application approval by EKOME lasts up to two months from the date of the application submission.

 

How long does it take for the subsidy amount to be allotted?

The payment process is concluded about 3 - 5 months from the date the application for payment has been submitted.

Is the amount of state aid by EKOME paid to the beneficiary subject to taxation or is it tax-free?

The amount of state aid does NOT increase the 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.

What is the cost of application submission?

For application submission a fee is required amounting to 0.0005 of the total amount of the estimated eligible costs. This amount may be no less than five hundred euros (€ 500) and no more than two thousand five hundred euros (€ 2,500).

For the submission of a request for a modification of the qualification decision, the payment of a fee is also required, the amount of which is set at 0,0002 of the eligible costs of the investment plan as defined in the qualification decision. This amount may be no less than two hundred euros (€ 200) and no more than one thousand euros (€ 1,000).

How are cultural criteria determined?

Cultural criteria are determined according to Law No. 4487/2017 of the Greek state and their fulfillment is an essential condition for an application to be either accepted or rejected.

The Implementing Body of the Investment Plan fills in all cultural criteria categories and proceeds with a substantiated self-assessment for each cultural criterion. Following the evaluation of the application for inclusion, the competent Committee for the Control of Legality and Evaluation of EKOME either accepts the score of the cultural criteria or changes it accordingly.

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

Eligible for inclusion to the cash rebate scheme for audiovisual works production supports feature films, documentaries, television series, animated films, and digital games.

The rebate does not apply to music concerts, recorded performances, sports events and shows, reality shows, recorded events, commercials, infotainment shows etc.

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 work.

The form of eligible expenses is defined explicitly in Annex 2 of the Joint Ministerial Decision 923/23-3-2018  and Joint Ministerial Decision 128/11-12-2018.  (invoices, payrolls, labour stamps, Analytical Periodic Statement – Insurance Fee). Eligible expenses are only those directly connected with the audiovisual work and have the work’s title on the legal documents that are submitted. 

Are the phases of production and post-production of an investment plan eligible for inclusion in the cash rebate scheme?

Eligible to apply for the Greek cash rebate are the following phases of an audiovisual production:

  1. The production phase
  2. The production and post-production phase
  3. The post-production phase
Are the expenses incurred during pre-production phase considered as eligible?

Eligible are all pre-production expenses incurred after the application submission.

Is there a minimum or maximum amount of eligible expenses?

The minimum amount of eligible expenses for the submission of an investment plan application is determined € 100,000. For TV series, the floor is set at € 30,000 per episode, and the total budget for all episodes should be no less than € 100,000.

There is no ceiling for eligible expenses.

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

If the expenses incurred are less than the approved ones, the investment plan will receive a smaller amount of state aid from EKOME.

A necessary condition is that the eligible expenses incurred correspond to no less than 60% of the budget approved by the inclusion decision published in the Government Gazette. If the investment plan has implemented less than 60% of its approved expenses, it loses any right to receive state aid from EKOME.

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

A non-exhaustive list of these documents is set out below:

  • A declaration that you accept the terms of the procedure
  • A contract signed by partners (co-production, contract with executive producer etc.)
  • Documents pertaining to your company’s operation such as the company’s Charter, income tax return statement, a certificate of good standing
  • A production plan and detailed budget for the expenses that will be incurred in Greece
  • A finalized financing plan listing all funding sources accompanied by the relevant contracts
  • A cultural criteria substantiated self-assessment
  • Full script or synopsis of the audiovisual work

A full list of all necessary documents to submit is included in Joint Ministerial Decision 128/14-12-2018 and in Annex 1 of Joint Ministerial Decision 923/23-3-2018  

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

Above the line expenses (copyright, screenwriting fees, production, music, direction, two leading roles) are eligible up to 25% 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.

Are the expenses incurred on alien cast and crew eligible?

Expenses paid to alien cast and crew are considered as eligible only when they are subject to taxation and insurance fees in Greece and they have a valid contract with a Greek production or production service company.

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

Travel expenses are eligible when the fares have been issued by a travel company subject to taxation and insurance fees in the Greek territory which issues the relevant legal documents.

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 eligible the expenses for a “pilot” production?

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

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

Marketing, promotion, and communication expenses, which are costs for promoting rather than producing an audiovisual project, are not included in the total eligible production expenses.

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).

C) in case of a “difficult” work, 80% of the total budget (including the state aid by ΕΚΟΜΕ).

What is a cross-border production?

A cross-border production is one that has been subsidized by more than one European state members and is produced by production companies from more than one of the European state-members.

What is a “difficult” audiovisual work?

A “difficult” audiovisual work is a single audiovisual work facing difficulties and production and promotion and fulfills the following requirements:

α) its sole prototype is in the Greek language

β) it is the first and/or the second work of a director, or the first and/or the second work of a producer

γ) has a budget of up to € 500,000

There is a specific category of cultural criteria (Table E, included in the Joint Ministerial Decision on the investment incentive), that specifies when an audiovisual work may be termed as "difficult", with a substantiated self-assessment by the Implementing Body which is afterwards evaluated by the competent Committee for the Control of Legality and Evaluation of EKOME.

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

A newly established production company may apply for state aid with the obligation to submit financial information for the period since its establishment. Companies under incorporation as well as consortiums also have the right to apply for the state aid. 

Is there a ceiling on the fees of the "Executive Company" on the total eligible budget?

The maximum eligible fee is set at 10% of the total eligible budget.

Is there a limit on shooting days?

There is no limit to the number of shooting days.

When drafting the budget for an audiovisual work, should the corresponding VAT be included?

The expenses presented in the budget of an audiovisual investment plan do NOT include Value Added Tax except for those related to fuel, accommodation and meals which are calculated with the relevant VAT.

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

The Investment Plan Entity may request an amendment of the approved eligible budget if it submits a request to www.ependyseis.gr before the concluding date of the investment plan.

Can I increase the total eligible budget with a request for amendment?

These requests are accepted if the general terms and conditions of inclusion are met. The request must be accompanied by a justification of its feasibility with a relevant technical description. Upon receipt of the request, and for it to be approved, a re-examination of the score of the cultural criteria received for the approved investment plan is required.

If there are discrepancies in the implementation of the investment plan among the 7 main categories above the percentage of 20%, but without changing the overall budget, is there a possibility of modifying the budget?

There is a possibility of modification in the budget categories if the amount of the total investment plan budget is not changed and the request for modification has been submitted before the final date of the investment plan.

If the locations and/or dates of filming change during the implementation of the audiovisual work, is a request for amendment required?

If the filming locations and/or filming dates change, a request for amendment must be made prior to the expiration date of the investment project. 

We have completed the filming of our audiovisual project. When should we submit an audit request?

An audit request may be submitted no later than six (6) months after the investment plan has been completed. The request should be submitted through www.ependyseis.gr website and be accompanied by the specified documents including an external audit report by a chartered accountant the cost of which shall be borne by the Implementing Entity. After the audit procedure by the pertinent EKOME commission concludes the decision is published in the Official Government Gazette and the state aid procedure will be activated.

Is all audit procedure completed through www.ependyseis.gr website and how can I upload large size files with documents to be audited?

In general, a file in physical form should first be submitted to EKOME, with the documents of expenses and their necessary accompanying documents (as described in the Audit Guide) and then the electronic Audit Request should be submitted to the State Aid Information System, with the accompanying supporting documents in electronic form. 

When and how may I submit the completed budget table and economic balance sheet?

They should be submitted in excel format, both in physical and electronic form, along with other supporting documents. You will find a model posted on www.ependyseis.gr.

How can one extend the period for an audit request submission?

The law makes no provision for an extension of the period the audit request should be submitted. However, if the investment plan has not expired, the Plan Implementing Entity may submit an amendment request to extend the investment plan duration by transferring its conclusion to a later date.

Is there anything I should pay extra attention to when submitting the audit request?

It is advisable to avoid finalizing the online Audit Request before resolving all your financial and technical questions! The Audit Manual directs you step by step through the whole process.

For any questions on technical matters or difficulties you might encounter during the audit request submission through the State Aid Information System you may contact EKOME at (+30) 214 4022526.

For more general financial and technical questions regarding the submission of the Audit Request, you can send your questions to the e-mail: cashrebate@ekome.gr. The investment plan management team will guide you directly. 

What documents does the Implementing Entity submit with the Audit Request?

To facilitate the investment Implementing Entities, EKOME has prepared and uploaded to www.ependyseis.gr (in the Information section) an Audit Request Guide, which clarifies the number and type of the necessary accompanying documents in order to submit an Audit Request.

It should be noted that the submission of the request includes two stages A) first a file in physical form is submitted to EKOME, with the expenses documents and their necessary accompanying documents (as described in the Audit Request Guide) and B) the electronic application is submitted to www.ependyseis.gr , with the accompanying supporting documents, in electronic form.

What exactly is the technical description of the investment plan in the Audit Request Guide-Documents, 3 (g)?

During the audit phase, you will indicate any deviations/modifications in relation to the Technical description of the investment plan that you have already submitted initially to the Application Form. That is, you can use your original text by adding the final variations and ending up with the final investment plan for implementation. If at some point, e.g. in (b) (scenario) no changes have occurred, you should state that at this point there has been no change in the original plan.

If the Audit Request has deficiencies, does this lead to rejection of the Request by the Audit Authority?

No, your request will not be rejected due to possible deficiencies, as they are identified and recorded during the audit process, so that you can be sent an e-mail by the Audit Authority, requesting the specific documents submission to EKOME. The Law provisions for a period of twelve (12) days after the receipt of the letter for handling and submitted the relevant documents to EKOME.

What should the physical folder submitted to EKOME include?

The physical folder includes:

a) the original documents stamped with the individual application number for all eligible expenses documents, as well as clear photocopies of the originals, with an equally clear proof of payment attached.

b) list of the documents to be submitted by the Implementing Entity as well as their payments (see standardized file "MODEL BUDGET AND BALANCE-SHEET" in the Audit Application Guide). To facilitate the audit, the specific table should be included in the electronic files uploaded by the Implementing Entity to the State Aid Information System in the phase of submitting the audit request,

c) the statement of suppliers' accounts   

d) the statement of the Implementing Entity current accounts

e) The USB 3.0 hard drive with audiovisual material documenting the fulfillment of cultural criteria

f) In case the regular staff of the Implementing Entity has worked for the specific investment plan, the printed file must include detailed timesheets with the hours dedicated to it (in relation to their total schedule).