Section 481 VFX uplift now in effect: key regulations and practical considerations

The eagerly awaited VFX uplift (formally known as the enhanced credit amount for visual effects) is now live in Ireland. Following approval by the European Commission in April 2026, the enhancement was subject to a commencement order, which has now been signed, with the ‘VFX uplift’ operational from 16 July 2026.

We previously outlined the proposed VFX uplift and the amendments to Section 481 TCA 1997 required to introduce the enhanced credit. Following commencement and the publication of the Regulations, further detail is now available on how the uplift will operate in practice.

Following the publication of S.I. No. 336 of 2026 Film (Enhanced Credit Amount for Visual Effects) (Amendment) Regulations 2026 (the Regulations) additional information is now available in relation to how the uplift will operate, as summarised below.

Transitional period applications

Where productions have already submitted an application for cultural certification under s.481 on or after 15 June 2026, this application can be revised to indicate intention to claim the VFX uplift. The deadline for submitting a revised application is 10 August 2026. Notably, only expenditure incurred after 10 July 2026 may be taken into account for determining:

1. Whether the minimum eligible VFX expenditure requirement of €1 million is met, and
2. The expenditure by reference to which the enhanced 40% tax credit is calculated.

Producer companies should ensure that a revised s.481 application is submitted to the Department of Culture, Communications and Sport (the Department) by the 10 August 2026 deadline where the project may qualify for the VFX uplift. We expect formal guidance and an updated application form to be provided by the Department shortly.

Relevant visual effects work

The Regulations specify the VFX processes which may meet the definition of ‘relevant visual effects work’ and these are listed below. As a reminder, one of the criteria to qualify for the VFX uplift is that the Irish production company must incur eligible expenditure on relevant visual effects work of at least €1 million.

• Project-specific planning and pipeline setup,
• Concept art, storyboarding and pre-visualisation,
• Tracking,
• Rotoscoping,
• Paint-outs, beauty work and cleanup,
• Compositing,
• Asset creation including modelling, sculpting, texturing and shading, rigging or character setup,
• CG animation including keyframe animation, motion capture, procedural animation or facial animation,
• Effects and simulation including particles and dynamics, cloth and hair simulation, destruction or rigid body simulations,
• Lighting,
• Rendering,
• Visual effects turnover,
• Visual effects editing,
• Colour correction for visual effects shots,
• Export and delivery of visual effects,
• Visual effects supervision, visual effects editorial and visual effects coordination, whether performed on set or in studio,
• LiDAR scanning and photogrammetry performed on set, and
• Virtual production.

The Regulations also provide that expenditure on production and post-production, supervision and coordination, and administration will not be considered eligible expenditure on relevant visual effects work (ie the expenditure used to calculate if the €1 million threshold is met) where such activities are not performed directly or indirectly in support of relevant visual effects work.

Conditional post-application qualification mechanism

The Regulations provide that where a producer company cannot demonstrate at the cultural certificate application stage that the qualifying company is expected to incur at least €1 million of eligible expenditure on relevant visual effects work, it is still possible to receive a cultural certificate noting that the VFX uplift may apply. In such cases, there will be an additional condition of the certificate that the producer company must:

• Notify the Department prior to completion of the qualifying film that the qualifying company expects to incur at least €1 million of eligible expenditure on relevant visual effects work, and
• As part of that notification submit completed Tab O and Tab P detailed below.

It’s noted that this mechanism is available to qualifying films within paragraph (b) of the definition of ‘visual effects project’ in s.481, ie where the qualifying company incurs eligible expenditure of at least €1 million on relevant visual effects work. On the face of it, the drafting appears broad enough to cover all s.481 projects which meet the €1 million VFX eligible spend requirement. However, Revenue has previously stated that the policy intention of paragraph (b) is to cover cases where the Irish production company incurs expenditure on both VFX work and other production work, as distinct from cases where the Irish producer company is itself a VFX house. Additional guidance from Irish Revenue in this regard would be welcome.

Administrative requirements

The Regulations amend Schedule 1 of the Film Regulations 2019 to provide two additional submissions which must be made as part of the application for cultural certification to the Department where the Irish producer company intends to avail of the VFX uplift (except in the circumstances outlined above). These are:

• Tab O – Schedule of Relevant Visual Effects Processes, and
• Tab P – Detailed Visual Effects Expenditure Plan

We’re expecting further guidance from the Department on the form of these submissions shortly.

 How Saffery can help

Saffery advises film, television and animation businesses on the application of Irish tax incentives, including Section 481. If you have any questions regarding the VFX uplift or its application to your production, please get in touch with Sinéad McHugh or Peter Boyle.