4.3 · Five countries, five different answers

BeginnerDuration ~13 min readTools One page, five lines

The big idea: there is no playbook to be intimidated by, because five states bought five different things with public money and not one of them got what the announcement promised.

The analogy

Every production has two documents about its money.

There is the one written for the announcement. It has a number in it, and the number is the biggest defensible version of the number. It is meant to be read by people who will not check.

And there is the one written for the closing. Who is owed what, in what order, what happens if it does not work, and which party is carrying the risk when it does not. Nobody quotes that one at a party. It is the only one that tells you what the deal is.

Every country in this lesson issued an announcement. Every one of them also produced a closing document, usually written by its own finance ministry, usually free to download, and usually saying something the announcement did not. This lesson is five closings.

How it works

Ireland bought production, and knows exactly what it paid.

Section 481 is the scheme everybody copies, and what they copy hardest is the refundable tax credit paid straight to the producer in cash, live since 2015. Under the older investor relief a headline rate of 41 percent reached producers as 26 to 28 percent, and the Department of Finance called the scheme inefficient and inequitable. The most imitated design feature in European film policy is a plumbing repair. Three Department of Finance cost-benefit analyses, all free, all negative: net -€40 million for 2015, -€72.4 million for 2016, -€78.54 million for 2020. The state’s defence deserves quoting rather than paraphrase: the net cost “may be considered the revealed value of the social and cultural dividend.” Ireland decided it was buying a culture, priced it, and kept buying. Irish Equity’s objection from inside is sharper: the real value does not exist at the point of production, it exists in copyright. That is the line between a service industry, which sells crew days on other people’s pictures, and an indigenous industry, which owns what it makes.

New Zealand bought a decade of somebody else’s production, and paid for it in employment law.

Name the thing first. On 29 October 2010, after three days of talks with a studio and the Prime Minister, Parliament passed a bill under urgency, 66 votes to 50, excluding film production workers from the definition of “employee.” It reversed the burden of proof and cancelled a Supreme Court ruling that a model maker on a Jackson production was an employee. The studio’s side is in the Prime Minister’s own press release: a rebate of up to US$7.5 million per picture, plus US$10 million against marketing.

Now the system that produced it. A state whose screen industry runs on inbound subsidy has one thing to negotiate with, the terms it is willing to change, because the only asset it owns is its statute book. The 2018 evaluation found the domestic grant returns NZ$0.68 for every dollar spent, and the ministry found no evidence of spillover from its largest incentive tier. Its additionality result for the newest scheme’s first year, meaning how much activity the money caused rather than subsidised anyway, reads “Nil.” Then Peter Jackson sold Weta Digital’s tools for US$1.625 billion in late 2021, and by December 2023 the buyer had laid off the entire staff. The state owned none of it, so two decades of subsidy could not stop that.

Nigeria bought nothing, because nobody was selling.

Nollywood was built on distribution first, through channels nobody had formalised, financed by market traders who were not film financiers. Production values arrived about fifteen years later, on almost no exhibition base. The number that matters most for a Filipino platform is not about production: a million Nigerian YouTube views earns roughly US$1,000 to $1,500, and the same million American views earns US$10,000 to $15,000. Audience geography, not audience size, is the revenue variable. What outlasted the venture capital, and two global streamers arriving and leaving on their own schedules, was YouTube channels the filmmakers owned outright.

Iran bought a children’s education institute, and got Cannes.

The lone-genius story is false here. Abbas Kiarostami’s early career was made inside Kanoon, an institute for the intellectual development of children founded in 1965. It existed to make work for children, so it funded films about children, which is why the aesthetic that later won a Palme d’Or is built around them. Jafar Panahi learned to run a camera there as a child. Institutions make auteurs, and this one was not a film institution. Constraint is a production method rather than an excuse: This Is Not a Film was made for €3,200, on a camcorder and an iPhone, in four days, by a director serving a twenty-year ban, and was shortlisted for an Oscar. The costs to individuals are severe, and Iranian art cinema and Iranian popular cinema are close to separate economies.

Colombia bought a supply of films, and did not get an audience.

The only case whose main fund is not financed out of general taxation. Ley 814 de 2003 created a parafiscal levy: 8.5 percent on exhibitors, 8.5 percent on distributors of foreign films, 5 percent on Colombian producers, declared monthly and collected by the national tax authority. Foreign films pay more than domestic ones, so the levy is protective by construction, and the industry funds itself instead of competing with hospitals for a budget line. It worked on its own terms: Colombian features went from 1.4 percent of theatrical releases to 9.6 percent. And Colombian coverage now carries the same headline every year: more national releases, fewer viewers. A fund can reliably manufacture films. Nothing shows it can manufacture viewers, which is what the 2016 Metro Manila Film Festival proved here with a total screen quota.

The bottom line, as a hostile room deserves to hear it. Every serious government evaluation in this dossier found a net economic cost. Ireland three times, New Zealand twice, each on its own arithmetic rather than a critic’s. Both states extended their schemes anyway, and both said openly that they were buying something other than a return. That is a legitimate choice made with the numbers in view. It is not the claim that circulates in industry advocacy, and a course meant to survive being fact-checked has to say so.

The receipts (evidence, if you want it)

This lesson is explainer-led and has no video, by design. Everything in it is statute text, ministry evaluations and trade reporting. The full five-country dossier, with the primary law texts retrieved in full, is the Film industry playbooks research page, and this lesson is one paragraph per case out of it.

Ireland. Section 481, Taxes Consolidation Act 1997, statute free at https://www.irishstatutebook.ie/eli/1997/act/39/section/481/enacted/en/html#sec481 . Core rate 32 percent of the lowest of eligible expenditure, 80 percent of total production cost, or the per-project cap, which has risen from €15 million in 2004 to €125 million for projects certified on or after 28 March 2024. Finance Act 2013 made the credit payable directly to the producer company from 1 January 2015. The leakage finding is in the Department of Finance’s Economic Impact Assessment of Section 481 Film Relief, December 2012, free: https://assets.gov.ie/193885/a2e8b485-c0dc-43e6-871a-bd50316f8c29.pdf , at paragraphs 0.16, 0.18 and 0.23, which record producers receiving 26 to 28 percent of a 41 percent headline rate, 74 percent of 2010 investors having income over €100,000, and the conclusion that the scheme “fails a cost benefit analysis, has a high level of inefficiency in terms of leakage and is inequitable.”

The three Irish cost-benefit analyses. 2012 EIA: “a substantial net welfare loss to society,” with a gain arising “only under extreme scenarios which are considered implausible.” 2018 Review IV, free mirror at https://www.screenproducersireland.com/media/pages/resources/policy-and-research/5018421500-1639511040/cost-benefit-analysis-s481-2018.pdf : net -€40 million for 2015 and -€72.4 million for 2016, and “there are no circumstances where there is a net benefit to society” at the stated shadow price of labour. 2022 CBA: net -€78.54 million for 2020, sensitivity range -€143.93 million to +€122.21 million. The “revealed value of the social and cultural dividend” line is the state’s own. The widely quoted “€1 generates €1.02” figure attributed to Olsberg SPI and Nordicity could not be located in the primary report and uses a different methodology from the Department of Finance analyses. It is not used here and should not be presented beside them.
The Irish labour dispute, correctly attributed. Three distinct bodies brought three distinct complaints to the Oireachtas Committee on Budgetary Oversight, whose May 2023 report is free at https://data.oireachtas.ie/ie/oireachtas/committee/dail/33/committee_on_budgetary_oversight/reports/2023/2023-05-09_report-on-section-481-film-tax-credit_en.pdf . The Irish Film Workers Association brought employment status and blacklisting. Irish Equity brought copyright and buy-outs, and the quoted line about value not existing at the point of production is theirs. Screen Guilds Ireland focused on skills and accreditation. The structural problem is that Section 481 requires a Designated Activity Company, a single-purpose vehicle that is the legal employer and need only exist for twelve months after completion. In December 2023 the Workplace Relations Commission awarded €434,216 to 22 members; in 2024 the Labour Court overturned all five appeals, finding no evidence the film company was the employer; in January 2025 members went to the High Court. In 2021 there were roughly 21,000 employments, of which 55 percent were extras, equating to about 3,265 full-time equivalents.
The service versus indigenous critique, open access under CC-BY: Denis Murphy, Maynooth University, Irish Journal of Arts Management and Cultural Policy, Vol 10(2), 2024, https://culturalpolicy.ie/index.php/ijamcp/article/download/2756/800/8034 . He records that the statute effectively equates cultural value with industry development and employment quality, that “there is no coherent definition of ‘quality employment’” anywhere in the legislation despite the credit being legally conditional on it, and that Screen Ireland stopped publishing labour expenditure after 2019. His cautionary parallel is Northern Ireland after Game of Thrones, where 12 percent of UK television drama spend fell to 1.4 percent by 2019.
New Zealand, the law. The bill was introduced under urgency on 28 October 2010 and passed 29 October 2010, 66 votes to 50. It amended section 6(1) of the Employment Relations Act 2000 to exclude film production workers from the definition of “employee,” with a new section 6(1A) restoring employee status only where a written agreement said so, reversing the burden of proof and neutralising Bryson v Three Foot Six Ltd, the Supreme Court decision of 16 June 2005. Ministry background, free: https://www.mbie.govt.nz/business-and-employment/employment-and-skills/employment-legislation-reviews/workplace-relations-in-the-screen-sector/background . What Warner Bros actually received is in Prime Minister John Key’s own press release of 28 October 2010, free: https://www.beehive.govt.nz/release/hobbit-movies-be-made-new-zealand , at up to US$7.5 million per picture plus US$10 million against marketing. The frequently cited “NZ$25 million” is not the primary-source figure; it is arithmetic across two pictures plus marketing. The Screen Industry Workers Act 2022, commenced 30 December 2022, restored collective bargaining, mandatory written contracts and tiered dispute resolution, but did not restore the Bryson test. Screen workers remain independent contractors by default.
New Zealand, the arithmetic. Sapere, Evaluating the New Zealand Screen Production Grant, March 2018, free: https://www.mbie.govt.nz/dmsdocument/1079-evaluating-screen-production-grant-pdf . Benefit per dollar of grant: 0.68 domestic, 2.35 international, 2.04 total, on a net fiscal cost of NZ$50.2 million. Sapere’s own caveats: the counterfactual is “relatively speculative,” the estimates “should be considered indicative only,” and “the industry does not appear to be sustainable without the grant.” Its additionality estimate is that without the grant 74.8 percent of domestic and 91.6 percent of international activity would be lost. The 2022 consultation document, free at https://www.mbie.govt.nz/dmsdocument/25415-increasing-value-from-government-investment-in-the-new-zealand-screen-production-grant , states at page 20 that “there is no quantitative evidence showing that New Zealand is getting spill-over economic benefits commensurate with this level of investment,” and at page 18 that large productions came “arguably at the expense of high-quality mid-sized productions.” The Budget 2025 major spending decisions report records inbound investment of about NZ$5.85 billion supported by around NZ$1.2 billion in rebates between 2014/15 and 2023/24, and gives the Year 1 additionality result as “Nil.” A commonly repeated claim that the New Zealand Treasury found the economic case weak could not be verified, because the Treasury site blocks automated access, and it is not used.
Weta. Wētā Workshop was founded in 1987 by Richard Taylor and Tania Rodger as a two-person operation. Peter Jackson sold Weta Digital’s tools division to Unity Software on 9 November 2021 for US$1.625 billion. On 25 November 2023 Unity and Wētā FX terminated their service agreement effective 10 December 2023, after Unity laid off the entire former Weta Digital staff. In August 2025 Wētā FX proposed cutting 100 Wellington roles. A claimed 2024 onward sale of the Weta tools to another studio has no supporting evidence and is treated as false pending a primary source.
Nigeria. Living in Bondage (1992), directed by Chris Obi Rapu and produced by Ken Nnebue, is regarded as the first Nigerian home video to achieve blockbuster success. The famous origin story, that Nnebue had surplus blank videotapes imported from Taiwan and shot a film to move the stock, traces only to secondary Nigerian outlets and is not stated as fact here, and the commonly quoted 750,000 copies figure could not be sourced to any primary or academic document. Video features existed before it, including Soso Meji (1988) and Ekun (1989). The name “Nollywood” traces to Matt Steinglass in the New York Times, 16 September 2002. Exhibition: roughly 23 cinemas and 100 screens for 170 million people in 2014; 218 screens and 5,432,537 admissions in 2019, which is 0.03 admissions per person per year. The YouTube economics, from Rest of World, 11 December 2023, free: https://restofworld.org/2023/nigera-filmmakers-youtube/ , give a million Nigerian views at roughly $1,000 to $1,500 against a million American views at $10,000 to $15,000, one filmmaker earning $3,500 from a film budgeted at about $1,200, ApataTV+ at 1.69 million subscribers and Libra TV uploading three films a week. Filmmakers name three reasons for choosing YouTube over streamers: control, piracy avoidance and dollar-denominated earnings. iROKOtv was founded in December 2010, launched December 2011, raised US$25 million, and shut its African web streaming service in June 2015 to survive on the diaspora. Amazon announced in January 2024 that it would stop funding local African originals. Netflix’s Nigerian pullback was widely reported in December 2024, denied publicly by Netflix, and corroborated at the level of reduced commissioning by later 2025 reporting. State it that way and do not assert a count of cancelled titles. The claim that Nollywood loses ten to fifteen billion dollars a year to piracy exceeds most estimates of the whole industry’s value and is not used.
Iran. Kanoon, the Institute for the Intellectual Development of Children and Young Adults, was founded on 8 January 1965. Its film unit produced Kiarostami’s The Bread and Alley (1970), The Traveller (1974), Where Is the Friend’s Home? (1987), Homework (1989) and And Life Goes On (1992), among others. Panahi assisted Kanoon’s library director in running a programme teaching children to operate a film camera. The Farabi Cinema Foundation was established in 1983; its specific mechanisms, subsidised stock, preferential exchange rates and import restrictions, are only partially verified here and should be sourced from Hamid Naficy’s A Social History of Iranian Cinema, Duke University Press, four volumes, print and paid. This Is Not a Film: €3,200, a digital camcorder and an iPhone, four shooting days over ten days in March 2011, made under a twenty-year ban, shortlisted for Best Documentary Feature at the 85th Academy Awards. The cake story is false. Panahi: “I have no idea who invented the story of the cake and for what purpose,” Hollywood Reporter, 20 May 2025. It went out on a USB drive. The cost to individuals: Panahi arrested March 2010, sentenced December 2010 to six years and a twenty-year ban, re-arrested July 2022, released February 2023 after a hunger strike, won the Palme d’Or on 24 May 2025 for It Was Just an Accident, was sentenced in absentia on 1 December 2025 to a year in prison plus a travel ban, returned to Iran in April 2026, and had the sentence upheld in June 2026. Mohammad Rasoulof was sentenced on 8 May 2024 to eight years plus flogging and confiscation of property, and left on foot through safe houses in a 28-day journey without a passport. Saeed Roustayi was sentenced in August 2023 for submitting a film to Cannes without permission, with mandatory attendance at courses on making films aligned with “national interests and national morality.” The honest limit: total Iranian box office in 2018 was US$23.8 million across 28.5 million admissions, average ticket revenue under a dollar, and the domestic audience favours comedies. The festival cinema and the commercial cinema are close to separate economies.
Colombia, from the primary law texts. Ley 814 de 2003, enacted 2 July 2003, full text free at https://www.funcionpublica.gov.co/eva/gestornormativo/norma.php?i=8796 . Article 5 creates the Cuota para el Desarrollo Cinematográfico: 8.5 percent on exhibitors on net ticket income after distributor and producer shares, 8.5 percent on distributors of non-Colombian films, and 5 percent on producers of Colombian features on their net exhibition income. Article 7 makes it monthly and gives the DIAN, the national tax authority, audit, assessment, penalty and coercive collection powers. Articles 9 and 10 route the proceeds to the Fondo para el Desarrollo Cinematográfico, administered under contract by Proimágenes, with the Contraloría General exercising fiscal oversight. Article 16 allows investors and donors to deduct 125 percent of the real value invested from taxable income, cash only, excluding advertising film and telenovelas. Ley 1556 de 2012, free at http://www.secretariasenado.gov.co/senado/basedoc/ley_1556_2012.html , adds a separate trade-ministry fund for inward investment, a 40 percent cash rebate on film services and 20 percent on hotels, food and transport, or alternatively a transferable 35 percent certificate that a foreign producer with no Colombian tax liability can simply sell. Paragraph 2 of Article 9 requires the producer to guarantee full Colombian labour rights to anyone hired in the country, which is one sentence doing what Ireland’s undefined “quality employment” condition has not managed in a decade of litigation.
Colombia, the outcome data, which is weaker and is flagged as such. Colombian features ran 36 in the eleven years after the previous state fund was liquidated, at 1.4 percent of theatrical releases, then 377 features between 2004 and 2020 at 9.6 percent, with domestic market share above 16 percent by 2016 to 2017 and a peak of 48 releases in 2019. These come from secondary compilation citing Proimágenes, because the Proimágenes site does not resolve from this course’s research environment at all. The audience criticism is verified only at headline level in Colombian press across 2024 to 2026, consistently reporting more national releases against fewer spectators, with article bodies unretrievable. Treat the direction as sound and any percentage as unconfirmed. El abrazo de la serpiente (2015), made for US$1.4 million, won the Art Cinema Award in Directors’ Fortnight at Cannes and became the first Colombian film nominated for an Academy Award.
What every one of these needed a state for, which matters for what comes next in this level: a refundable tax credit needs a revenue authority able to pay out more than it collects; a parafiscal levy needs a legislature and a tax authority to enforce it; rewriting employment law needs a parliament; and statistical infrastructure is a state function whose abandonment takes years to become visible. Both Ireland and New Zealand demonstrate that last one in the negative. Screen Ireland stopped publishing labour expenditure after 2019, New Zealand disestablished its official screen industry survey, and by December 2025 the New Zealand agencies were reporting in their own foreword that they “no longer ha[ve] access to the quality, up-to-date data needed.”

The Film industry playbooks research page carries all five cases in full, including the verification gaps list that names every claim on this page that is not yet safe to broadcast. The one-page comparison below adds Korea and states the honest bottom line.

Six national playbooks, comparednational-playbooks-comparison.pdf155 KBCourse original, formatted from the Hope research pages

Your one move

Five lines. One per country, on one page, in your own words.

For each: what it proves, in one sentence, and what copying it here would require, in one sentence. The second half is the one that does the work, so be specific. A legislature. A tax authority. A parliament willing to sit under urgency. Nothing at all.

Then one line at the bottom, on the tax credit finding, written as you would say it to somebody in the room who has just quoted an industry press release at you.

Thirty minutes. Done when six lines exist and at least one of the five says the requirement is a legislature.

Want to go further?

Add Korea from the last lesson as a sixth line, on the same two questions. Then rank all six by how much of the requirement already exists in the Philippines today.

You will find that the ranking is not the same as the ranking by how impressive the outcome was, and that gap is the most useful thing on the page.

The needle: the genealogy this course keeps naming is a question about who pays whom, on what condition, and with what discretion. Every case here is that question with a different answer written into a statute. Colombia named the payers in a numbered article. New Zealand’s answer was to move the cost onto the worker, in forty-eight hours, in writing. None of these is a fact about the character of Irish or Nigerian or Colombian people, and neither is the arrangement you grew up inside.

Terms introduced

Check

You can move on when you can… name what each of the five cases actually proves, and state what every serious government evaluation in the dossier found about tax credits.

Go deeper

Next up: 4.4 · It has already worked here, which stops pointing abroad. Hope that only points at other countries is its own kind of contempt, and there is domestic evidence with receipts attached.
The Film industry playbooks research page is this lesson at ten times the length, with the statute texts, the ministry evaluations and the cross-case synthesis. Its final section is a list of everything in the dossier that is not yet verified enough to broadcast, which is the most useful page in the Library if you are building anything from this material.
If you open one document from this lesson, make it Ireland’s 2018 cost-benefit analysis. It is free, it is a government arguing with its own film policy in public, and reading a state publish a negative number about a programme it intends to keep is a specific kind of education in how these decisions actually get made.