IncentivesProduction Guide

The Cultural Test: How Films Qualify for International Incentives

Nick HartyBy Nick HartyUpdated September 14, 20267 min read

Quick answer

A cultural test is the check a country uses to decide whether a film is culturally national enough to claim its incentive. Most award points for content, where the work is done, and the nationality of the creative team and crew, with a pass mark. The UK's BFI film test needs 18 of 35 points, Canada's CPTC needs 6 of 10 creative points, and France's TRIP rebate requires passing a genre-specific cultural test.

On this page
  1. Two kinds of incentive, two kinds of rules
  2. The UK: 18 of 35 points
  3. Canada: 6 of 10 key creative points
  4. France: a genre-specific test for TRIP
  5. Australia: significant Australian content
  6. Ireland
  7. Co-production treaties: the other way in
  8. Content rules in the US
  9. Planning the points

A production that moves to London or Toronto for the incentive sometimes finds out in prep that location alone doesn't get it the money. The incentive belongs to films that count as British, Canadian, or French, and the country decides that with a cultural test. Some tests are generous enough that an American story shot at a UK studio with a mostly local crew passes easily. Others reward local ownership and local creative leads, and a service production can't pass them at all.

This post walks through how the main tests score and how producers plan points before signing deals. For the broader question of whether to shoot abroad, read why productions shoot overseas.

Two kinds of incentive, two kinds of rules

Before scoring anything, work out which kind of program you're looking at.

Programs that support national content usually carry a cultural test or ownership rules. The production often has to be controlled by a local producer and hire locals in the lead creative roles. Canada's Canadian Film or Video Production Tax Credit (CPTC) and Australia's Producer Offset are examples.

Programs built to attract foreign productions usually drop the content test and pay on local spend or local labor. Canada's Production Services Tax Credit (PSTC) pays on qualified Canadian labour with no content points. Australia's Location and PDV Offsets have no nationality requirement for crew, though they come with spend thresholds.

The UK sits in between. Its Audio-Visual Expenditure Credit is open to international productions through a UK company, but the film still needs BFI certification, either by passing the cultural test or as an official co-production. France's TRIP rebate for international productions also requires a cultural test.

The UK: 18 of 35 points

The BFI's cultural test for film has four sections, and a film needs 18 of 35 points to pass:

SectionMaximum pointsWhat it looks at
A: Cultural content18Setting, characters, story or subject matter, and the language of the original version
B: Cultural contribution4How the film represents or reflects British creativity, heritage, or diversity
C: Cultural hubs5Where shooting, VFX, and post-production take place
D: Cultural practitioners8Nationality or residence of the director, writers, producers, composer, lead cast, heads of department, and crew

Sections C and D together are worth 13 points, and they're the ones producers control through where they shoot and whom they hire. Section A depends on the script. The BFI's guidance notes break each section into sub-items; use them to score your specific project.

A worked tally

Here's an illustrative score for a US-financed period drama set in 1960s Paris, shot and posted at a UK studio, with an English-language script. The section maximums are the BFI's; the scores are an estimate a producer might make before applying and should be checked against the guidance notes.

SectionMaxEstimated scoreReasoning
A: Cultural content184English language; not set in the UK; one British lead character
B: Cultural contribution40No particular British heritage angle
C: Cultural hubs55Principal photography, VFX, and post all in the UK
D: Cultural practitioners88UK-resident director, writer, composer, most lead cast, heads of department, and crew
Total3517One point short of 18

At 17, the film fails. The producer's options before hiring are specific: make sure the British lead's role is significant enough to count, or find a British subject angle in the story. If the director is American instead, the practitioner points drop and the film is further away. The practical rule is to score the test from the draft cast and crew list, then lock the deals that protect the points.

Passing the test certifies the film as British. The money still depends on qualifying spend. Per HMRC, AVEC pays 34% on most films (53% on qualifying independent films) and qualifying expenditure is limited to the lower of 80% of total core costs or UK core costs. The credit is taxable. The United Kingdom page covers the numbers.

Canada: 6 of 10 key creative points

The CPTC is for Canadian productions controlled by Canadian producers, and CAVCO scores live action projects on key creative positions, per its application guidelines:

PositionPoints if Canadian
Director2
Screenwriter2
Highest-paid lead performer1
Second highest-paid lead performer1
Director of photography1
Art director1
Music composer1
Picture editor1

A production needs at least 6 points. Either the director or the screenwriter must be Canadian, and at least one of the two highest-paid lead performers must be Canadian. There are cost tests too: at least 75% of the costs for services must be paid to Canadians, and at least 75% of post-production costs must be for services provided in Canada.

A tally for a Toronto-produced thriller with an American star:

PositionCanadian?Points
DirectorYes2
ScreenwriterNo0
Lead 1 (the US star)No0
Lead 2Yes1
DPYes1
Art directorYes1
ComposerNo0
EditorYes1
Total6

It passes at exactly 6, with the director requirement and the one-Canadian-lead requirement met. If the producer later swaps the second lead for another American actor, the film loses a point and also fails the lead-performer rule, so it can't qualify however the other positions score. Casting decisions on a CPTC film are also incentive decisions.

A foreign production with no Canadian creative control doesn't use the CPTC at all. It uses the PSTC, which pays 16% of qualified Canadian labour, plus provincial service credits. See the Canada page.

France: a genre-specific test for TRIP

France's Tax Rebate for International Productions pays 30% of eligible French expenditure, or 40% for projects with more than €2 million of French VFX spend, capped at €30 million per project, according to Film France. To qualify, live action projects have to shoot at least 5 days in France and spend at least €250,000 in France (or 50% of the budget), and pass a cultural test specific to live action, animation, or VFX. The tests include elements related to French culture, heritage, and territory.

The practical effect is that French settings, French subject matter, and French locations help. A project shooting a few days of Paris exteriors for a story set in Paris is in a different position from one using a French stage to stand in for somewhere else. Film France, a department of the CNC, is the first contact and publishes the scoring grids. See France.

Australia: significant Australian content

Australia's Producer Offset, which pays 40% of qualifying Australian production expenditure for cinema features and 30% for other eligible formats, requires a project to have significant Australian content (SAC) or be an official co-production, per Screen Australia. SAC isn't a points table. Screen Australia makes a judgment looking at factors such as the subject matter, where the project was made, and the nationality and residence of the people who made it, as set out in its guidelines.

International productions that can't meet SAC use the Location Offset or PDV Offset instead, which don't test content. Shooting in Australia compares all three, and the Australia page has the thresholds.

Ireland

Ireland's Section 481 credit requires a cultural certificate from the Minister before the film starts, and producers request the Scéal Uplift for lower-budget features at the same stage. See Ireland for the current rates and conditions.

Co-production treaties: the other way in

When a film can't pass a cultural test on its own, an official co-production treaty can make it national in each partner country. The BFI says a film certified as an official co-production can qualify for the UK expenditure credit without passing the cultural test, and Australia's Producer Offset accepts official co-productions in place of SAC. Treaties have their own minimum financial and creative contributions for each partner, so the points problem doesn't disappear; it moves into the co-production agreement.

Content rules in the US

US state incentives generally don't use cultural tests, but some have content provisions. Texas is the clearest example. The Senate Research Center's analysis of S.B. 22 describes the Texas film office as authorized to deny an application because of inappropriate content or content that portrays Texas or Texans in a negative fashion, to review proposed content during the application, and to review final content before payment. That means a Texas production has content risk at both ends of the process. See Texas.

Planning the points

  1. Identify which program you're chasing and whether it has a content test, ownership rules, or neither.
  2. Score the test from the draft script, cast list, and crew list, before any key deal is signed.
  3. Find the cheapest points to add: a local head of department, post in-country, a local composer.
  4. Build the points into deal memos. A replacement for anyone counted in the test has to hold the same points.
  5. Apply for interim or provisional certification early, since lenders want it before advancing against the incentive.
  6. Keep documentation of nationality and residence for every counted person.

The cultural test glossary entry has a short definition and a separate example, and the incentive calculator estimates the credit once you know the film qualifies. Storiara's Funding module lists matching programs from a built-in incentives list based on the project's locations, shoot days, and budget, but it doesn't assess cultural tests, so certification questions go to the film office or your incentive counsel.

Frequently asked questions

How many points do you need to pass the UK cultural test for film?

18 out of 35, according to the BFI. The points come from four sections: cultural content (up to 18), cultural contribution (up to 4), cultural hubs (up to 5), and cultural practitioners (up to 8).

What are the Canadian content points for the CPTC?

CAVCO awards up to 10 points for Canadians in lead creative roles on live action: director 2, screenwriter 2, each of the two highest-paid lead performers 1, and 1 each for the director of photography, art director, composer, and picture editor. A production needs 6 points, a Canadian director or screenwriter, and at least one Canadian among the two highest-paid leads.

Does every incentive have a cultural test?

No. Service incentives aimed at foreign productions often don't. Canada's Production Services Tax Credit has no Canadian content points test, and Australia's Location and PDV Offsets have no nationality requirement. Programs designed to support national content, like the UK credit, Canada's CPTC, and Australia's Producer Offset, usually do.

Can a co-production skip the cultural test?

Often. The BFI says a film certified as an official UK co-production can qualify for the expenditure credit without passing the cultural test, and Australia's Producer Offset accepts official co-productions in place of the significant Australian content test. Each treaty has its own requirements.

Can a US state reject a film because of its content?

Some can. Texas law authorizes its film office to deny a grant application because of inappropriate content or content that portrays Texas or Texans in a negative fashion, and the office reviews both proposed and final content.

Sources

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Nick Harty

Nick Harty

Technical Lead, Storiara

Technical architect and full-stack engineer building the core systems that power Storiara. Creates technology that enhances creative workflows.