How Togra handles Section 481A (digital games)

# How Togra handles Section 481A (digital games)

The Digital Games Corporation Tax Credit. Where each step lives in Togra, and the three places it behaves unlike the film credits.

1. The shape of it

32% of the lowest of eligible expenditure, 80% of qualifying expenditure, and €25,000,000 — a maximum of €8,000,000 per game. Minimum €100,000 of qualifying expenditure, but only at the final claim. Sub-contractor payments capped at €2,000,000 per game. State aid, including this credit, may not exceed 50% of the development budget.

It applies only to projects typed Videogame, and it lives behind the opt-in Cluiche module. A film, TV drama, animation or creative documentary goes to §481; unscripted formats go to §487A. One project carries exactly one of the three, and Togra enforces that rather than trusting it.

2. Three ways it is not a film credit

The claim unit is the accounting period, not the project. The interim credit is claimed on the Form CT1 for the period in which the expenditure was incurred, within 12 months of that period's end. A four-year game therefore has four claims. Togra models those periods explicitly on the tracker, each with its own deadline.

The €25M cap is a lifetime ceiling for the game, not a per-period allowance. Togra tracks headroom across every claim and clips accordingly, so a long project cannot quietly draw the maximum four times over. A withdrawn claim releases its headroom again.

The budget is Regulation 9's five cost heads, not a chart of accounts. Employee costs, capital assets, equipment rental, consumables and IP, and sub-contractors. Each line also records where the money was spent, because eligible expenditure is the State-or-EEA portion of qualifying expenditure. Two whole stages are excluded outright: designing the initial concept, and debugging or maintaining a completed game.

3. The expensive things Togra watches

The interim-expiry cliff. An interim certificate is valid for three years. If it expires with no final certificate issuing, §481A(8) treats it as though it never had effect and every interim claim already made is withdrawn — money received and spent. The tracker and the submissions log both alert on this, with the amount at risk in euro, well before the date.

The six-month final application window. From completion — the date the game is released to the public, or delivered to a commissioning party — you have six months to apply for final certification (Regulation 4).

The 28-working-day DCCS target. Unlike §487A, the Department publishes one. A pending application older than that is flagged. A rejected or incomplete application restarts the clock from resubmission, so record the resubmission date or the age will read as worse than it is.

Expenditure that can never be included. Anything met by grant aid, anything already claimed under the R&D credit, and anything already claimed under the film credit. Togra flags these per line and asks you to confirm rather than deciding for you — grant aid may fund a part of the project that is not in the claim, and Togra does not model the R&D credit at all, so a computed "clean" answer there would be a claim it cannot support.

4. The Culture Test

35 points, pass at 14, with minimums of 3 in Section A, 3 in B and 4 in C. Section D is supplemental and has no minimum. Three criteria are compound and are the ones worth understanding:

• A3 awards 2 points if any one of seven cultural-inspiration criteria is met. They are alternatives, not seven separate points.
• B4 awards 2 points only if the composer is Irish or EEA and the music is either an original composition or a new arrangement. Two points or none, never one.
• C2-A is worth 8 points, one per named position — Producer/Project Manager, Lead Writer, Technical Director, Lead Programmer, Creative Director, Lead Designer, Art Director, Lead Artist/Animator. It is the single biggest block in the test.

The trap the scorer exists to catch: clearing 14 points does not mean passing. A game can reach the pass mark on Section C alone and still fail because A and B have their own floors. Togra always shows the section position alongside the total.

5. The application

Two packs, because the Department publishes two forms:

• Interim — Tabs 1–6: application form, synopsis, Person Days Schedule, the two director's declarations, and the undertaking in respect of quality employment.
• Final — Tabs 1–8, adding Tab 7 (the interim certificate's conditions were complied with) and Tab 8 (PEGI rating or IFCO confirmation of exempt status).

On Tab 8: a PEGI rating of 16 or lower is itself evidence of exempt status. PEGI 18, and every other circumstance including no rating recorded, needs confirmation from IFCO. Togra computes which case you are in.

The Person Days Schedule is the Department's own workbook — the same one §481 uses for its Tab E. Togra fills it from the employee and sub-contractor cost lines, banded Irish / EU / Non-EU, with the eligible column reduced by the €2M sub-contractor ceiling so it agrees with the claim.

Anything Togra does not hold prints as [to complete], never as a plausible-looking value. These documents go to a government department.

6. Post-release content — approved, not yet in force

Finance Act 2025 extends §481A to post-release content for up to three years after release, and extends the scheme itself to 31 December 2031. The European Commission approved the post-release change on 28 July 2026. It is not in force: the supporting regulations are still in development and the Minister for Finance's commencement order has not issued. The Revenue TDM (January 2025) and the DCCS Guidance Note (August 2025) both still exclude post-launch content.

Togra shows the three-year window so you can plan, and calculates nothing on it. When the order issues, one constant switches it on.

7. What does not apply

A game project has no call sheets, no stripboard, no shooting days, no cast, no unit moves. Those surfaces are hidden for a Videogame project rather than adapted, and nothing is deleted — change the project's type and they all return.