- Guide2 of 5
- The lawITAA 1997, ss 376-10 to 376-50
- Checked9 October 2026
The location and PDV offsets: 30% each, certified by the Arts Minister
The location offset and the PDV offset are each 30% of a company’s qualifying Australian production expenditure (QAPE): on the whole film for the location offset, and on the post, digital and visual effects work for the PDV offset. For both, the Arts Minister, not Screen Australia, determines that expenditure and issues the certificate.
General information only, not tax or legal advice. The certificate comes from the Arts Minister under the Act; the offset is claimed in the company’s income tax return, so the Australian Taxation Office is the other official place to check.
The two offsets, side by side
| Rule | Location offset | PDV offset |
|---|---|---|
| Rate | 30% of total QAPE on the film (s 376-15) | 30% of total QAPE on the film, to the extent it relates to post, digital and visual effects production (s 376-40) |
| 30% applies to | Films whose principal photography, or for an animation its making, commenced on or after 1 July 2023 (replacing 16.5%) | PDV production commencing on or after 1 July 2011 (replacing 15%) |
| Spending floor | Total QAPE of at least $20 million (s 376-20(5)(a)), replacing $15 million for films whose principal photography, or for an animation its making, commenced on or after 1 July 2023 | PDV QAPE of at least $500,000 (s 376-45(5)(a)) |
| Television series | The amount worked out under s 376-20(6), from total QAPE and the series’ length in hours, must be at least $1.5 million, replacing $1 million from the same date | No such floor in s 376-45 |
| Work in Australia | The company carried out, or arranged, all the activities in Australia necessary for making the film | The company carried out, or arranged, all the activities in Australia necessary for the PDV production |
| Also needed | A contract for some or all of the film’s PDV work with an Australian resident (or a foreign resident with a permanent establishment here and an ABN, if all or part of the PDV work it provided was provided at or through that establishment), under which work was provided and counts as QAPE; and the training spend below | Nothing further in s 376-45 |
The resident PDV contract condition applies to PDV work provided under a contract on or after 1 July 2023, whenever the contract was signed. The training condition applies to films whose principal photography, or making, commenced on or after 1 July 2024.
Which films qualify
Both offsets use the same tests of type. The film must be produced for exhibition in cinemas or by television broadcasting, or for distribution to the public as a video recording, and be a feature film or a film of a like nature, a mini-series of television drama, or a television series. It must not be, or not to a substantial extent be:
- a documentary, where it is a feature film or a mini-series;
- an advertising program or a commercial;
- a discussion program, quiz program, game show, panel program, variety program or a program of a like nature;
- a film of a public event;
- “a film forming part of a drama program series that is, or is intended to be, of a continuing nature”, where it is a feature film or a mini-series;
- a training film;
- a computer game.
A television series needs 2 or more episodes under a single title, with a common theme, dramatic elements that form a narrative structure, made to be shown together for a national market or markets. The Act notes that “A documentary can be a television series.” For the location offset, the series’ principal photography must also fit within 12 months, or its making within 36 months for an animation, pilot episodes aside.
The training spend (location offset only)
Section 376-27(6) sets the minimum training expenditure by the film’s production commencement day:
- on or after 1 July 2024 but before 1 July 2025: “the lesser of $250,000 and 0.5% of the company’s total QAPE on the film”;
- on or after 1 July 2025: the lesser of $500,000 and 1% of total QAPE.
Regulations may replace both figures with a prescribed amount of no more than $750,000 and a prescribed percentage of no more than 1%, always as a pair. At least half of the minimum must itself be QAPE on the film. The spend can be QAPE on film-making training, provided in Australia, for someone who has worked on, or is working on, the film; or payments to a provider of tertiary courses or VET accredited courses that include such training, made after the production commencement day and before the making of the film, or the company’s QAPE on it, ends, whichever is earlier. The provider must not be an associate of the company.
Two exemptions replace the spend. Under s 376-28, the company has materially contributed to establishing or upgrading permanent film infrastructure in Australia that is reasonable in scale, cost and location, is done at least partly after production began, will be finished within a reasonable time if not yet complete, and has eased capacity constraints in the screen industry; it applies to infrastructure completed on or after 1 July 2024. Under s 376-29, a trainee who worked on the film trained under a program during that work, the company or an associate paid for it, and the program materially contributed to this film, to at least 2 films made substantially in Australia, and to easing capacity constraints in the Australian screen industry.
What counts as PDV
“Post, digital and visual effects production for a film means:
(a) the creation of audio or visual elements (other than principal photography, pick ups or the creation of physical elements such as sets, props or costumes) for the film; and
(b) the manipulation of audio or visual elements (other than pick ups or physical elements such as sets, props or costumes) for the film; and
(c) activities that are necessarily related to the activities mentioned in paragraph (a) or (b).”
Income Tax Assessment Act 1997, s 376-35(2). Its note gives 3D animation, digital compositing and music composition and recording as examples.
Dealing with the Minister
Before setting a location offset QAPE or issuing that certificate, the Arts Minister may ask in writing for information relevant to the decision or to the film’s benefit to the Australian screen industry, allowing at least 30 business days. The time can be extended on request; if the information is not provided in time, the Minister may refuse.
A company is entitled to only one of the three film offsets for a film. Either offset is lost once another film offset certificate has issued for the film, and the claim, made in the tax return of an Australian resident or a foreign resident with a permanent establishment here and an ABN, is irrevocable.