This is how contracting
works in Visualnet

By opening the Procurement File in Adobe Acrobat Reader, the «Signatures» panel automatically displays the issuer’s advanced electronic signature, based on a qualified certificate, and the qualified timestamp issued by the FNMT-RCM TSA. The verification is mathematical and is performed automatically by Reader when the document is opened, without the reader needing any technical knowledge or supplementary software. The certificate chain of the timestamp is validated against the European Trusted List registered under the eIDAS Regulation.

The first page of the Procurement File is designed precisely for that situation: it identifies what the document is, the regulation that backs it, and how to verify its electronic signature in Adobe Acrobat Reader without additional software. If the inspector requires complementary technical validation, the Procurement File includes a documentary validation support channel they may contact.

The certificate chain of the qualified timestamp can be verified independently by any authority through the European Trusted List registered under the eIDAS Regulation. The verification is mathematical and reproducible.

No. No technology platform and no professional advisor can guarantee the outcome of a specific administrative procedure. What the Procurement File documents, under the eIDAS Regulation, is the procurement process followed: the date on which the document existed and the integrity of its content since then, a chained audit trail over which the platform holds no modification or deletion permissions, and the traceability of the process.

The final qualification of the expenditure by the authority depends on additional factors — the quality of the commercial documentation, the correlation of the expense with economic activity, the interpretative criterion of the inspector — that exceed the scope of the Procurement File and that each production company’s tax advisor evaluates in its specific context.

The Procurement File carries an advanced electronic signature based on a qualified certificate of a legal representative issued by FNMT-RCM, and a qualified time stamp. Under Art. 41.2 of Regulation (EU) No 910/2014, the qualified time stamp enjoys the presumption of the accuracy of the date and time it indicates and of the integrity of the document since then. In Spain, Art. 326.4 of the Civil Procedure Act (Ley de Enjuiciamiento Civil) governs the evidence of electronic documents in which qualified trust services have been used. The presumption covers the fact that the Procurement File existed on that date and has not changed since; it does not cover the truthfulness of its content.

The NISR 4400 report issued by a ROAC-registered auditor is an optional additional layer, not a requirement for the Procurement File to deploy its own probative value.

No. The Procurement File documents the competitive procurement process — which suppliers were invited, which bids were received, how each request was awarded. The invoice of the awarded supplier, the service contract and the bank payment receipt remain, under the Spanish Invoicing Regulation (Royal Decree 1619/2012) and Article 106 of the General Tax Law, the mandatory commercial documentation that the production company must keep.

The Procurement File complements that support with evidentiary documentation of the procurement process that gave rise to the invoice — it does not replace it.

The Procurement File is provided as documentary evidence of the procurement process, alongside the standard tax documentation that the inspection has required — invoices, contracts, payment receipts, accounting books. Its added value emerges when the inspection raises substantive questions: whether there was a competitive process, whether the price reflects the market, whether transactions with related parties were conducted at arm’s length, or whether the basis of the Article 36 LIS deduction is built on auditable eligible costs.

The first page of the Procurement File itself identifies the document, its probative value under Regulation (EU) 910/2014, and the instructions for verifying the electronic signature for the inspector.

Yes, as documentation of the procurement process. The Procurement File identifies the companies invited, the bids received, the award and, when the chosen bid is above the average, its justification, with a qualified time stamp and chained traceability through SHA-256 hashes and a gapless sequence number, which make detectable any alteration of an event's recorded content or the deletion of any event. The AEAT can check that the expenses in the base are real and justified —as a rule, with an invoice (Art. 106.4 LGT)— and, where there are related parties, that they are valued at market.

The production company also keeps the standard commercial documentation — invoice, contract, payment receipt — on which the effective amount of the deduction is calculated.

It is one of the cases in which the Procurement File is most useful. Article 18 LIS requires transactions between related parties to be valued at market value, and the AEAT can request documentation that the price actually paid was formed under those conditions.

The Procurement File documents that the related supplier was invited on equal terms together with all active directory companies with that activity in the country of the shoot, that the price awarded was compared with the bids received and that the result was kept in the chained record at close. Order ECD/2784/2015 only recognises as a cost of a film the expenses invoiced by each company related to the producer up to €50,000 for feature films (€4,000 for short films), and provided they are in line with the market, which is justified with three bids unless there are not enough entities in the market (Art. 2.3.c). The Procurement File records how many bids there were, also when there are fewer than three.

In cases where the regulation itself expressly requires it — the special report recognising the cost of the film before the ICAA under Order ECD/2784/2015 (as amended by Order CUD/553/2023), equivalent cases under the foral regimes of the Basque Country and Navarre and under the Canary Islands REF —, or when the production company values adding a layer of independent professional review on top of the technical substrate of the Procurement File.

In those cases, the Procurement File acts as the underlying documentation on which the audit firm applies the previously agreed procedures in accordance with NISR 4400 (the International Standard on Related Services for Agreed-Upon Procedures Engagements). The two documents are cumulative, not alternative.

Yes. The Procurement File is designed to be a cross-cutting documentary piece: the same document, with a qualified time stamp, can be provided on the different fronts —the base of the Article 36 LIS deduction before the AEAT, the ROAC auditor's special report before the ICAA under Order ECD/2784/2015, and the equivalent files in the foral regimes and in the Canary Islands regime—, together with the commercial documentation each one requires.

The Use Limitation section of the Procurement File itself delimits the circle of authorised recipients — auditors, financiers, tax authorities and administrative bodies with a legitimate interest. The multi-jurisdictional regulatory map on this same page develops each of those fronts.

The Procurement File carries an advanced electronic signature based on a qualified certificate of a legal representative issued by FNMT-RCM, and an EU-qualified time stamp under Regulation (EU) No 910/2014 (eIDAS). Both the certificate and the time stamp come from qualified trust service providers on the EU trusted list. The signature and the time stamp can be checked technically from any country, with Adobe Acrobat Reader and no additional software.

The Procurement File is provided as documentary support of the procurement process followed. The NISR 4400 report issued by a ROAC-registered auditor on the Procurement File is an additional professional layer where appropriate; it is not a requirement for the Procurement File to document the process.

Yes, as documentation of the process. Since 1 January 2024, the Audio-Visual Expenditure Credit (AVEC) replaces Film Tax Relief and High-End TV Tax Relief. New productions use it from 1 April 2025, and all productions from 1 April 2027. It requires at least 10% of core expenditure to be used or consumed in the UK, and the credit is calculated on that UK expenditure, capped at 80% of total core expenditure. The standard rate is 34%; 39% for animation and children's television; and 53% for low-budget independent film. It is set out in the Finance Act 2024 and administered by HMRC. The BFI certifies that the work is British (cultural test), which is a condition of the credit; the expenditure is reviewed by HMRC.

The Procurement File documents line by line the companies invited, the bids received and the price awarded, with the number of companies invited in each activity. The Production Company can provide it, with its accounting records, if HMRC reviews the expenditure claimed.

Section 7 of the UK Bribery Act 2010 makes a company liable when a person associated with it bribes to obtain or retain business or an advantage for the company, even if the company did not know. An associated person is someone who performs services for or on behalf of the company: an employee, an agent, a subsidiary; this is decided by the circumstances of each case, not by the type of relationship (section 8). The law allows the company to defend itself by proving that it had adequate procedures in place to prevent it. The Ministry of Justice guidance (March 2011) identifies six principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication (including training) and monitoring and review.

In film and TV procurement, the Procurement File documents a structured, non-discretionary process, the recorded invitation to directory companies with the activity in the country of the shoot and a SHA-256 chained record. The organisation and its auditors assess which part of their adequate procedures they can support with that documentation.

The United Kingdom is one of the main destinations for service production for the major US studios: in 2025, inward investment in film and high-end TV totalled £5.8 billion (BFI). When a British production company acts as service producer for a listed American studio, its procurement decisions can be relevant to several frameworks: the Bribery Act, if an associated person bribes; IRC §482, if studio and production company are related entities; the FCPA, if there are payments to foreign officials; and, if the studio is listed, its SOX certifications, which cover the companies it consolidates.

The Procurement File, with an advanced electronic signature based on a qualified certificate and an EU-qualified time stamp under Regulation (EU) No 910/2014 (eIDAS), documents that procurement process, and the production company and the studio can provide it to their auditors. The regulatory map on this same page sets out each of the frameworks.

The Procurement File is provided as complementary documentary evidence alongside the standard commercial documentation — invoices, contracts, payment records, qualifying expenditure certifications — that HMRC or the BFI requires in a compliance check or cultural review. Its added value emerges when the inspector raises substantive questions about the procurement process: whether the procurement was competitive, whether the prices reflect real UK market rates for the activity and shooting dates, whether the expenditure was used or consumed in the UK, or whether the basis of the expenditure credit is built on auditable costs.

The first page of the Procurement File itself identifies the document, its probative value under Regulation (EU) 910/2014, and the instructions for verifying the electronic signature in Adobe Acrobat Reader without additional software. If the inspection requires complementary technical validation, the Procurement File includes a documentary validation support channel they may contact.

When the listed American financing studio asks for an independent professional review for its SOX §404 assessment. When a British co-producer or financier asks for an additional professional review through agreed-upon procedures. When the British production company itself considers it for internal governance. In those cases, the Procurement File acts as underlying documentation on which the audit firm applies the previously agreed procedures in accordance with NISR 4400 (the IAASB's revised ISRS 4400).

It is an international standard for agreed-upon procedures engagements, not an assurance engagement. The two documents are cumulative, not alternatives: the Procurement File documents the process even if the NISR 4400 report is not issued; the report sets out the findings of the agreed-upon procedures when the transaction or the end client justifies it.

The Procurement File carries an advanced electronic signature based on a qualified certificate and a qualified timestamp, under Regulation (EU) 910/2014 (eIDAS). In the United States, the Electronic Signatures in Global and National Commerce Act (ESIGN Act, 15 U.S.C. §7001 et seq.) and the Uniform Electronic Transactions Act (UETA), adopted by forty-nine states, the District of Columbia, Puerto Rico and the Virgin Islands, establish that legal effect may not be denied to a signature or a record solely because it is in electronic form. The Procurement File is therefore provided as documentary evidence of the procurement process.

The integrity of the Procurement File and the date of its time stamp can be checked by any third party —the IRS, the DOJ, the SEC or a state film office— through the signature panel in Adobe Acrobat Reader, with no additional software. The NISR 4400 report issued by a ROAC-registered auditor is an additional professional layer where appropriate; it is not a requirement for the Procurement File to document the process.

It can be. IRC §482 allows the IRS to adjust the price of transactions between related entities when it is not the one independent parties would have agreed. Purchases from independent suppliers are not related-party transactions, although they can count as costs when setting the price between the studio and its production company. In the US the best method rule applies, and for services the comparable price method is the CUSP method (Treas. Reg. §1.482-9(c)).

The Procurement File documents the companies invited, the bids received and the position of the awarded price within the range of the bids received. If an adjustment exceeds certain thresholds, the penalty is 20% of the underpayment attributable to that adjustment, or 40% in the most serious cases (IRC §6662(e) and (h)); pricing documentation that exists when the return is filed, and is provided within 30 days if the IRS requests it, can avoid it. The studio and its adviser assess whether the Procurement File forms part of that documentation.

The FCPA prohibits paying or promising anything of value to a foreign official to obtain or retain business, and requires companies listed in the US to keep books and records that reflect their transactions in reasonable detail and to maintain a system of internal accounting controls. The accounting provisions apply to the issuer, which is responsible for what it consolidates; the anti-bribery provisions apply to issuers, US companies and anyone acting in the US. The FCPA does not set market prices for purchases.

The Procurement File documents the production's procurement process —recorded invitation to directory companies, bids received in a closed environment and recorded award, with justification when the chosen bid is above the average or at the maximum—, with an advanced electronic signature based on a qualified certificate and an EU-qualified time stamp under Regulation (EU) No 910/2014 (eIDAS). The issuer and its auditors assess whether it forms part of their controls.

If the studio is listed in the US, its CEO and CFO certify each periodic report they file with the SEC and their responsibility for the controls (SOX §302). Management assesses internal control over financial reporting every year and, in larger listed companies, it is audited by a PCAOB-registered auditor (SOX §404). That assessment covers the companies the studio consolidates, not an independent co-producer or service production company.

The Procurement File, generated automatically without discretionary intervention, with a chained record and an advanced electronic signature based on a qualified certificate, documents the production's procurement; the issuer and its auditor assess whether to include it in their internal control.

For the company to be liable for a payment made through a third party —an agent, an intermediary or a joint venture partner—, the FCPA requires that it knew, or was aware of a high probability, that it would occur (§78dd-1(f)(2)). The law provides no defence for having had controls; the DOJ and the SEC take the compliance programme into account when deciding whether and how to act.

The Procurement File, signed at project level with the co-producer's procurement decisions —companies invited, bids received and award with justification—, documents that process, with an advanced electronic signature based on a qualified certificate and an EU-qualified time stamp under Regulation (EU) No 910/2014 (eIDAS). The regulatory map on this same page sets out each framework.

State tax credit programmes —Georgia Film Tax Credit, California Film & Television Tax Credit Program, New York State Film Production Tax Credit, Louisiana Motion Picture Production Tax Credit, New Mexico Film Production Tax Credit and Illinois Film Production Services Tax Credit, among others— are administered by the respective state film offices or departments of revenue, with eligibility criteria, qualifying expenditure limits and audit procedures that vary from state to state.

Each state sets which expenditure qualifies, how it is evidenced and who reviews it; several require a report from an independent certified public accountant (CPA). The Procurement File provides uniform procurement documentation on which that CPA can work, with the same structure regardless of the state of the shoot.

The Procurement File is provided as complementary documentary evidence alongside the standard tax and accounting documentation that the inspection has required — Form 1120 schedules, transfer pricing documentation under IRC §6662(e), books and records under §13(b)(2)(A) of the Securities Exchange Act, qualifying expenditure statements of the corresponding state program. Its added value emerges when the inspection raises substantive questions about the procurement process: whether there was competitive procurement, whether prices reflect real market rates, whether transactions with related parties were documented contemporaneously, or whether the procurement decisions respond to automated internal controls.

The first page of the Procurement File itself identifies the document, its probative value under Regulation (EU) 910/2014, and the instructions for verifying the electronic signature in Adobe Acrobat Reader without additional software. If the inspection requires complementary technical validation, the Procurement File includes a documentary validation support channel they may contact.

When the listed financing studio includes the report in its SOX §404 assessment as a review by a professional third party. When a transaction between related entities requires pricing documentation under IRC §6662(e) and the issuer prefers an early professional review. In those cases, the Procurement File acts as underlying documentation on which the audit firm applies the previously agreed procedures in accordance with NISR 4400 (the IAASB's revised ISRS 4400).

ISRS 4400 is comparable to the AICPA's AT-C 215 (SSAE 19): both are agreed-upon procedures engagements in which the auditor reports findings on previously agreed procedures, without expressing an assurance opinion. The two documents are cumulative, not alternatives: the Procurement File documents the process even if the NISR 4400 report is not issued; the report sets out the findings of the agreed-upon procedures when the transaction or the end client justifies it.