Europaudvalget 2011-12
EUU Alm.del Bilag 188
Offentligt
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European CommissionDG CompetitionInformation, communication & mediaB-1049 Brussels
Ministry of Culture2 NybrogadeDK-1203 Copenhagen KTelFaxE-mailWeb::::+45 33 92 33 70+45 33 91 33 88[email protected]www.kum.dk
16 December 2011
Contribution from the Danish government on the European Commissions consultationon assessing State aid for films and other audiovisual worksThe Danish government welcomes the European Commissions consultation on assess-ing State aid for films and other audiovisual work. To fulfil the potential – both eco-nomic and cultural – of the film and audiovisual industry in the Member States it isnecessary to have contemporary State aid assessment criteria for support for producingfilms and audiovisual works.In general the Danish government recommends that the Cinema Communication willbe object for a review that brings a new Cinema Communication in line with the devel-opment in the film and audiovisual industry and the effects of the digital revolution onthe industry. This without losing the focus on European films as a strong cultural prod-uct which creates a unique cultural diversity among the member states.More specific the Danish government would like to comment on to the following topicsset by the Commission:Why do we fund film?Public subsidy is important to sustain European film production. Films play an impor-tant role in shaping European identities and they reflect the cultural diversity of thedifferent traditions and history of the Member States.By the same time audiovisual works and films are economic goods offering opportunitiesfor the creation of wealth and employment. Films are a part of the creative industry andare contributing to the EU 2020-strategy.The film production therefore has a twofold face that has to be recognised in the CinemaCommunication.
Doc. No. 1107170
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Subsidy race to attract major film productionThe Commission is expressing concern on competition among Member States to usestate aid to attract inward investment from large scale, mainly US, film productioncompanies.The Danish State aid is given to the film production and not through tax incentives orother measures to facilitate the production of international films in particular territo-ries. This can be done on a regional level.The Danish government is not aware of the extent of the use of public subsidies thatcould lead to a subsidy race among the Member States. But a higher transparency forthese schemes could be needed as an overview of the numbers of European and US filmsthat are subsidised by these schemes.On this question the Commission should be aware of not disturbing the conditions forEuropean co-production and bilateral treaties with third countries.About “cultural test” and other methods for defining film as culture it is the opinion ofthe Danish government that it is the Member States themselves that should definewhat constitutes culture and not the be defined in the Cinema Communication. That’salso counts for the setting of the conditions for receiving the subsidies.The scope of the Cinema CommunicationAs mentioned by the Commission some Member States offer support for activities otherthan film and audiovisual production, including film distribution and film promotion,which are not covered by the Cinema Communication.The Danish government would like to see an extension of the scope of the CinemaCommunication to cover the whole value chain of a film production from development toproduction and consumption.It is also the opinion of the Danish government that there is a need to reconsider thedefinition of audiovisual works covered by State aid criteria of the current CinemaCommunication which are limited to films and TV productions. Here there is a need toincorporated new types of audiovisual works such as cross-media. In particular interac-tive works such as video games should be assessed using the same criteria as for filmsand televisions productions.Territorial conditionsThe Danish State aid is given as support for film productions that reflects Danish cul-ture and contributes to develop the Danish film industry. Denmark has no territorialcriteria in our film support schemes.
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The current Cinema Communication allows Member States to insist that up to 80% ofthe production budget of a subsidised film production is spent in the Member State of-fering the aid.The Danish government would like to draw the attention to the fact that is the decisionof the Member States themselves if they want to use this opportunity. We will encour-age the Commission not to overregulate on this subject.