‘Scotland:
be brave’
Pamela Collie CA wants Scotland to shout louder about its achievements in the creative sector. In conversation with ICAS Director of Tax Katie Close CA, she explains how tax incentives are rewriting the script for the industry and how building an ecosystem of post-production companies could hold the key to further success
‘Scotland:
be brave’
Pamela Collie CA wants Scotland to shout louder about its achievements in the creative sector. In conversation with ICAS Director of Tax Katie Close CA, she explains how tax incentives are rewriting the script for the industry and how building an ecosystem of post-production companies could hold the key to further success
“The creative sector is absolutely a success story for Scotland. And I think we need to be a bit prouder of what Scotland has done,” says Pamela Collie CA.
The sector’s value to Scotland is estimated to be worth around £5.7bn – with the screen sector set to generate around £1bn alone by 2030–31 – but Pamela believes there is opportunity for growth.
In her role as a partner at accounting and advisory firm S&W, Pamela works closely with independent production companies, both established and up and coming, across media and entertainment. She also has an in-depth knowledge of the UK’s creative tax incentive regime and is one of S&W’s media and entertainment sector leads, working with colleagues to support clients and develop the firm’s presence in the industry.
During the course of this interview, conducted by ICAS Director of Tax Katie Close CA, she explains how Scotland’s creative sector could continue to thrive but also why it risks losing out to other countries if it doesn’t act soon.
And aside from their expert knowledge on tax, both Katie and Pamela boast a degree in English Literature from the University of Glasgow, and share a passion for the country’s creative sector.
Katie: Scotland’s creative sector is such an interesting area, but one that I don’t think we really talk about a lot. I’m interested to hear your thoughts on the current status of tax reliefs for the creative sector.
Pamela: There are tax reliefs across film, TV and video games. They’re the same for all types of films (released in cinemas) and video games, but then when you get into TV, there is what’s called high-end TV (scripted TV programmes – such as dramas, comedies and documentaries – that meet specific financial, duration and cultural requirements), kids’ TV and animation.
They’re now taxable above-the-line credits, so they’re mechanically very similar to the Research and Development Expenditure Credit (RDEC) – the UK tax incentive designed to reward businesses for investing in science and technology innovation.
So the calculation is a bit like RDEC, only more generous. The base rate is 34%, but it can go up to 39% for kids’ TV and animated films, animated TV programmes and VFX spend. There’s also an independent film tax credit with specific criteria, which has a headline rate of 53%.
Katie: How does Pillar Two affect those reliefs for the creative sector?
Pamela: There was a lot of work done across taxpayers, practice and HMRC to ensure that the regime stayed competitive while also addressing any concerns around opportunities to abuse it. It effectively went from a 25% non-taxable credit to a 34% taxable credit. So it was just grossed up. In general, it’s been pretty successful in maintaining the generosity and attractiveness of the regime.
“The UK as a whole uses tax incentives as a really good way to ensure it is an attractive and competitive jurisdiction to produce big-budget films”
Katie: How important do you think these tax incentives are for determining where investment takes place?
Pamela: They are genuinely really important. The UK as a whole uses them as a really good way to ensure it is an attractive and competitive jurisdiction to produce big-budget films. Films that we would traditionally have thought of as Hollywood films, like the DC movies, are shot just outside London now. And the Marvel film, Avengers: Doomsday, was shot in London. Obviously, in Scotland, we had Frankenstein filming in 2024, Spider-Man: Brand New Day last year and The Batman: Part II this summer.
The US has state-level tax incentives. There’s never been a federal incentive, but there’s now a bipartisan bill to introduce a federal incentive, which will be stackable on top of the state-level incentives.
There was recently a policy roundtable with the Department of Culture, Media and Sport, hosted by the British Screen Forum, to discuss what this could mean for the UK. Will we have to do something else to maintain competitiveness? At the moment, the key thing for the UK is that the criteria are very clear: if you meet the criteria, you get the tax refund. So, everyone factors it into their investment decisions, and they can make a clear judgement on whether to film in the UK because they know they will get a 34% tax credit versus filming in one of the states in America or Canada.
A simplistic way of looking at it is that if you invest £2m, you’re almost guaranteed to get a percentage of that money back, whether the film is a success or failure, or whether it’s even released. So you’re de-risking investment into the creative sector.
Katie: It’s not always the case that you see direct consequences from tax policy, but here it seems like there is a direct consequence, which I think is really powerful. And you’re talking about it in terms of actually supporting that creative sector. In Scotland, we have a lot of films and TV shows that are shot here, and we’ve got gaming companies like Rockstar North. But I guess the challenge is: how do we keep those people in Scotland? How do we train people to work in that industry? How can we make Scotland attractive to these creative businesses when the Scottish government doesn’t have any particular power over those tax reliefs?
Pamela: One of the reasons why I’ve been looking at this is because while the creative sector is absolutely a success story for Scotland – based on a 2023 survey, Scotland’s screen sector alone accounted for more than 12,000 jobs and remains on track to deliver £1bn to the Scottish economy by 2030–31 – recent research by the Film and TV Charity says that 22% of people in the industry are experiencing sustained worklessness. This means they’ve worked for fewer than three months in the year. Almost half of the people in the industry are looking at taking steps to leave it, and once you lose them, they may not come back.
Scotland unfortunately has a recent precedent to turn to in this area – during the downturn in the energy sector, many skilled young people left in search of opportunities elsewhere. Almost 14,500 people, including 16% of 20- to 29-year-olds, left Aberdeen between 2010 and 2020, including me. Once talent disperses, rebuilding those skills, networks and experience becomes difficult and expensive.
Screen Scotland does have its own limited budget, so there are subsidies that you can access if you are filming in Scotland or making a Scottish production.
I understand the fiscal realities – you can’t simply say ‘we want more money’ – but there are things that the Scottish government could do to maximise the impact of the funds they have available.
There’s a Production Growth Fund for Scotland, which can give you between £200,000 and £500,000 if you are making a production in Scotland. It uses similar criteria to the types of productions that qualify for the Audio-Visual Expenditure Credit (AVEC), which is the UK-wide scheme.
Glasgow stood in for Gotham City during filming of The Batman: Part II
Glasgow stood in for Gotham City during filming of The Batman: Part II
But it’s a long set of criteria that effectively says this will encourage the committee to look favourably on your application. You send it all in, but there’s a cap on the fund. So you don’t know if there’s any money left when you submit the application, and you don’t know if you’re going to get that funding.
So ultimately, when I talk to a lot of producers about it, they say, ‘I can’t factor it into my investment decisions. I can’t look at coming to Scotland versus filming somewhere else.’ It’s not driving investment behaviour into Scotland; it’s just giving people who have already decided to film in Scotland a wee bit of extra money.
As part of the application process, you are encouraged to phone Screen Scotland and chat through what you’re doing, and they will tell you how to strengthen your application. I would like to hope that in that conversation, they would tell you if there was no money left!
In contrast, AVEC has a very clear set of criteria, so you know whether you will qualify and receive funding.
Katie: We’ve seen some universities shutting down creative courses. From a personal perspective, I hold the humanities and the creative sector quite dear to my heart. So, what do we need to do to keep those creative skills in Scotland, but also attract people from elsewhere?
Pamela: What the best tax incentives do isn’t necessarily about getting individual productions like Batman. It’s great that it was filmed here, but how many creative sector jobs in Scotland did that actually give us? It gives a boost to the Scottish economy through hotels and everything else, but it’s really about how you build that ecosystem. How do you have enough infrastructure so that when people look at what to study at university, there’s a clear career path? Is there a job there when I graduate, and is it in Scotland so that I can stay here or move here?
“There’s no reason why post-production and unscripted TV can’t be based in Glasgow, or that Dundee can’t be an international games hub”
The collapse of game developer Build A Rocket Boy, based in Edinburgh (and formerly Dundee), shows why it’s about having a critical mass of companies. Moving to a place where there are a lot of those jobs means if one particular role doesn’t work out, there are other places you can go.
There are a few things I’ve been looking at around tax incentives, specifically where Scotland can differentiate itself from London. One area that’s particularly interesting is post-production.
Katie: Scotland’s creative sector is such an interesting area, but one that I don’t think we really talk about a lot. I’m interested to hear your thoughts on the current status of tax reliefs for the creative sector.
Pamela: There are tax reliefs across film, TV and video games. They’re the same for all types of films (released in cinemas) and video games, but then when you get into TV, there is what’s called high-end TV (scripted TV programmes – such as dramas, comedies and documentaries – that meet specific financial, duration and cultural requirements), kids’ TV and animation.
They’re now taxable above-the-line credits, so they’re mechanically very similar to the Research and Development Expenditure Credit (RDEC) – the UK tax incentive designed to reward businesses for investing in science and technology innovation.
So the calculation is a bit like RDEC, only more generous. The base rate is 34%, but it can go up to 39% for kids’ TV and animated films, animated TV programmes and VFX spend. There’s also an independent film tax credit with specific criteria, which has a headline rate of 53%.
Katie: How does Pillar Two affect those reliefs for the creative sector?
Pamela: There was a lot of work done across taxpayers, practice and HMRC to ensure that the regime stayed competitive while also addressing any concerns around opportunities to abuse it. It effectively went from a 25% non-taxable credit to a 34% taxable credit. So it was just grossed up. In general, it’s been pretty successful in maintaining the generosity and attractiveness of the regime.
“The UK as a whole uses tax incentives as a really good way to ensure it is an attractive and competitive jurisdiction to produce big-budget films”
Katie: How important do you think these tax incentives are for determining where investment takes place?
Pamela: They are genuinely really important. The UK as a whole uses them as a really good way to ensure it is an attractive and competitive jurisdiction to produce big-budget films. Films that we would traditionally have thought of as Hollywood films, like the DC movies, are shot just outside London now. And the Marvel film, Avengers: Doomsday, was shot in London. Obviously, in Scotland, we had Frankenstein filming in 2024, Spider-Man: Brand New Day last year and The Batman: Part II this summer.
The US has state-level tax incentives. There’s never been a federal incentive, but there’s now a bipartisan bill to introduce a federal incentive, which will be stackable on top of the state-level incentives.
There was recently a policy roundtable with the Department of Culture, Media and Sport, hosted by the British Screen Forum, to discuss what this could mean for the UK. Will we have to do something else to maintain competitiveness? At the moment, the key thing for the UK is that the criteria are very clear: if you meet the criteria, you get the tax refund. So, everyone factors it into their investment decisions, and they can make a clear judgement on whether to film in the UK because they know they will get a 34% tax credit versus filming in one of the states in America or Canada.
A simplistic way of looking at it is that if you invest £2m, you’re almost guaranteed to get a percentage of that money back, whether the film is a success or failure, or whether it’s even released. So you’re de-risking investment into the creative sector.
Katie: It’s not always the case that you see direct consequences from tax policy, but here it seems like there is a direct consequence, which I think is really powerful. And you’re talking about it in terms of actually supporting that creative sector. In Scotland, we have a lot of films and TV shows that are shot here, and we’ve got gaming companies like Rockstar North. But I guess the challenge is: how do we keep those people in Scotland? How do we train people to work in that industry? How can we make Scotland attractive to these creative businesses when the Scottish government doesn’t have any particular power over those tax reliefs?
Pamela: One of the reasons why I’ve been looking at this is because while the creative sector is absolutely a success story for Scotland – based on a 2023 survey, Scotland’s screen sector alone accounted for more than 12,000 jobs and remains on track to deliver £1bn to the Scottish economy by 2030–31 – recent research by the Film and TV Charity says that 22% of people in the industry are experiencing sustained worklessness. This means they’ve worked for fewer than three months in the year. Almost half of the people in the industry are looking at taking steps to leave it, and once you lose them, they may not come back.
Scotland unfortunately has a recent precedent to turn to in this area – during the downturn in the energy sector, many skilled young people left in search of opportunities elsewhere. Almost 14,500 people, including 16% of 20- to 29-year-olds, left Aberdeen between 2010 and 2020, including me. Once talent disperses, rebuilding those skills, networks and experience becomes difficult and expensive.
Screen Scotland does have its own limited budget, so there are subsidies that you can access if you are filming in Scotland or making a Scottish production.
I understand the fiscal realities – you can’t simply say ‘we want more money’ – but there are things that the Scottish government could do to maximise the impact of the funds they have available.
There’s a Production Growth Fund for Scotland, which can give you between £200,000 and £500,000 if you are making a production in Scotland. It uses similar criteria to the types of productions that qualify for the Audio-Visual Expenditure Credit (AVEC), which is the UK-wide scheme.
Glasgow stood in for Gotham City during filming of The Batman: Part II
Glasgow stood in for Gotham City during filming of The Batman: Part II
But it’s a long set of criteria that effectively says this will encourage the committee to look favourably on your application. You send it all in, but there’s a cap on the fund. So you don’t know if there’s any money left when you submit the application, and you don’t know if you’re going to get that funding.
So ultimately, when I talk to a lot of producers about it, they say, ‘I can’t factor it into my investment decisions. I can’t look at coming to Scotland versus filming somewhere else.’ It’s not driving investment behaviour into Scotland; it’s just giving people who have already decided to film in Scotland a wee bit of extra money.
As part of the application process, you are encouraged to phone Screen Scotland and chat through what you’re doing, and they will tell you how to strengthen your application. I would like to hope that in that conversation, they would tell you if there was no money left!
In contrast, AVEC has a very clear set of criteria, so you know whether you will qualify and receive funding.
Katie: We’ve seen some universities shutting down creative courses. From a personal perspective, I hold the humanities and the creative sector quite dear to my heart. So, what do we need to do to keep those creative skills in Scotland, but also attract people from elsewhere?
Pamela: What the best tax incentives do isn’t necessarily about getting individual productions like Batman. It’s great that it was filmed here, but how many creative sector jobs in Scotland did that actually give us? It gives a boost to the Scottish economy through hotels and everything else, but it’s really about how you build that ecosystem. How do you have enough infrastructure so that when people look at what to study at university, there’s a clear career path? Is there a job there when I graduate, and is it in Scotland so that I can stay here or move here?
“There’s no reason why post-production and unscripted TV can’t be based in Glasgow, or that Dundee can’t be an international games hub”
The collapse of game developer Build A Rocket Boy, based in Edinburgh (and formerly Dundee), shows why it’s about having a critical mass of companies. Moving to a place where there are a lot of those jobs means if one particular role doesn’t work out, there are other places you can go.
There are a few things I’ve been looking at around tax incentives, specifically where Scotland can differentiate itself from London. One area that’s particularly interesting is post-production.
Education
Studied English literature at the University of Glasgow
2010
Joined EY as a graduate
2013
Qualified as a CA
2016
Promoted to senior manager and moved to London
2018
Moved to New York to become an International Tax Senior Manager
2021
Moved back to the UK as a director at EY
2026
Joined S&W as an International Tax Partner
Education
Studied English literature at the University of Glasgow
2010
Joined EY as a graduate
2013
Qualified as a CA
2016
Promoted to senior manager and moved to London
2018
Moved to New York to become an International Tax Senior Manager
2021
Moved back to the UK as a director at EY
2026
Joined S&W as an International Tax Partner
There is a post-production fund, Project Post Fund, which is quite small for Scotland, but more and more post-production companies are appearing because, by its nature, the work is more location-agnostic. If Scotland were to focus on things like VFX, animation and virtual production, all of those companies would create year-round employment. They invest in workforce development, and they generate IP that can be commercialised internationally.
It’s also where screen and gaming intersect. With all the new technology being developed, it’s unlikely that we will continue to neatly divide between film, TV, gaming and digital media.
People can move from working on a game to working on post-production for a sci-fi film. There’s a lot of crossover, which allows you to build that ecosystem.
Katie: The Scottish government wants a very resilient economy and wants the tax base to grow. That is important for all sorts of things – for example, block grant funding is based on how fast our tax base is growing. So this idea of an ecosystem in the creative sector is actually quite critical, and it’s critical in other industries as well. If one business collapses, workers can move around. What would be your advice to the Scottish government to support this ecosystem around post-production companies?
Pamela: Scotland does have some inherent challenges around studio space, and if you want to go and film in the Highlands, you’re going to have to pay for accommodation for everyone, which is expensive. But it is what it is.
There’s little point in competing directly with incentives in London – giving companies an extra £100,000 probably isn’t going to make the difference. So, what is the UK government not focusing on? Post-production is one area, but also unscripted shows like The Traitors and The Hit List, which are filmed in Scotland. While unscripted TV doesn’t have the same prestige as high-end films, those shows can run and run.
Longevity is a major advantage for unscripted shows like The Traitors
Longevity is a major advantage for unscripted shows like The Traitors
People often talk about charging for access to the landscape, which I understand. But will most American audiences know whether something was filmed in Scotland or Ireland? Arizona, for example, has a very distinctive landscape. They got rid of their tax credit because they thought people would want to film there anyway. What happened was that everyone moved production to New Mexico, so Arizona ultimately reintroduced the credit.
I’m conscious that we can’t fix everything, but I worry that because it is such a complex problem, we’re currently not fixing anything. None of the things I’ve suggested will necessarily turn everything around overnight into a flood of filming in Scotland, but I think they will help, and they are within the Scottish government’s power to implement.
Also, Scotland has a fantastic creative legacy, and we don’t shout about it enough. We need to be a bit prouder of what Scotland has done, get the Scottish government to stand up and promote it more, and secure what we need from Westminster. It’s currently a ‘quiet success’ story, and I find that really odd.
Gaming companies like Rockstar North are a big part of Scotland’s success story
Gaming companies like Rockstar North are a big part of Scotland’s success story
Katie: Are there any other countries you think are doing a really good job of supporting the creative sector through tax investment?
Pamela: Ireland is doing very well at the moment. They are looking at the UK and Canada and asking, ‘What can we do to differentiate ourselves?’ We have to remain competitive. I’m not suggesting a race to the bottom on costs with Eastern Europe or India, but we have to show that we are a viable, cost-effective alternative to places like California, offering advantages in crew base, location, time zone and so on.
One thing people continually mention to me is the UK Internal Market Act, arguing that we can’t do anything that looks like we are trying to take jobs from London.
But I don’t think we are. You can have the big-budget films and big studios located just outside London, but there’s no reason why post-production and unscripted TV can’t be based in Glasgow, or that Dundee can’t be an international games hub. We’re not just competing internally, either. That US bipartisan bill is designed to keep more of the screen sector in the States.
We’re competing with them, but we’re also competing with Finland, Estonia, the Middle East and India. They all recognise the value of the creative sector, making it an increasingly global competition.
Scotland is so well placed to take advantage of this. But if we don’t shout about it and get the right government support and infrastructure in place, we risk being left behind.
Music quiz show The Hit List, filmed in Glasgow, is another programme with the potential to keep running
Music quiz show The Hit List, filmed in Glasgow, is another programme with the potential to keep running
Katie: My final question: how important do you think financial literacy is for building a strong creative arts sector in Scotland?
Pamela: It’s incredibly important. According to a report by Creative UK, the creative industry faces four times higher barriers to funding than almost any other industry. That issue multiplies when you go outside London, and it multiplies further for women-led companies. The gap between founder-led, entrepreneurial creative businesses and traditional private equity funds or institutional lenders is huge. They just don’t speak the same language. A lot of what I’ve wanted to do has been around work with those fast-growing indies to help bridge that gap.
So part of it is education on the funder side regarding creative infrastructure and the value of IP. So much of the value in creative businesses is tied up in intellectual property, and companies need to understand the deals they are entering into so they aren’t signing over their IP to a private equity fund.
On the other side, there’s the investment readiness piece, because so many of the barriers stem simply from the fact that both sides aren’t speaking the same language.
swgroup.com/people/pamela-collie
Discover ICAS’ policy positions in relation to tax
There is a post-production fund, Project Post Fund, which is quite small for Scotland, but more and more post-production companies are appearing because, by its nature, the work is more location-agnostic. If Scotland were to focus on things like VFX, animation and virtual production, all of those companies would create year-round employment. They invest in workforce development, and they generate IP that can be commercialised internationally.
It’s also where screen and gaming intersect. With all the new technology being developed, it’s unlikely that we will continue to neatly divide between film, TV, gaming and digital media.
People can move from working on a game to working on post-production for a sci-fi film. There’s a lot of crossover, which allows you to build that ecosystem.
Katie: The Scottish government wants a very resilient economy and wants the tax base to grow. That is important for all sorts of things – for example, block grant funding is based on how fast our tax base is growing. So this idea of an ecosystem in the creative sector is actually quite critical, and it’s critical in other industries as well. If one business collapses, workers can move around. What would be your advice to the Scottish government to support this ecosystem around post-production companies?
Pamela: Scotland does have some inherent challenges around studio space, and if you want to go and film in the Highlands, you’re going to have to pay for accommodation for everyone, which is expensive. But it is what it is.
There’s little point in competing directly with incentives in London – giving companies an extra £100,000 probably isn’t going to make the difference. So, what is the UK government not focusing on? Post-production is one area, but also unscripted shows like The Traitors and The Hit List, which are filmed in Scotland. While unscripted TV doesn’t have the same prestige as high-end films, those shows can run and run.
Longevity is a major advantage for unscripted shows like The Traitors
Longevity is a major advantage for unscripted shows like The Traitors
People often talk about charging for access to the landscape, which I understand. But will most American audiences know whether something was filmed in Scotland or Ireland? Arizona, for example, has a very distinctive landscape. They got rid of their tax credit because they thought people would want to film there anyway. What happened was that everyone moved production to New Mexico, so Arizona ultimately reintroduced the credit.
I’m conscious that we can’t fix everything, but I worry that because it is such a complex problem, we’re currently not fixing anything. None of the things I’ve suggested will necessarily turn everything around overnight into a flood of filming in Scotland, but I think they will help, and they are within the Scottish government’s power to implement.
Also, Scotland has a fantastic creative legacy, and we don’t shout about it enough. We need to be a bit prouder of what Scotland has done, get the Scottish government to stand up and promote it more, and secure what we need from Westminster. It’s currently a ‘quiet success’ story, and I find that really odd.
Gaming companies like Rockstar North are a big part of Scotland’s success story
Gaming companies like Rockstar North are a big part of Scotland’s success story
Katie: Are there any other countries you think are doing a really good job of supporting the creative sector through tax investment?
Pamela: Ireland is doing very well at the moment. They are looking at the UK and Canada and asking, ‘What can we do to differentiate ourselves?’ We have to remain competitive. I’m not suggesting a race to the bottom on costs with Eastern Europe or India, but we have to show that we are a viable, cost-effective alternative to places like California, offering advantages in crew base, location, time zone and so on.
One thing people continually mention to me is the UK Internal Market Act, arguing that we can’t do anything that looks like we are trying to take jobs from London.
But I don’t think we are. You can have the big-budget films and big studios located just outside London, but there’s no reason why post-production and unscripted TV can’t be based in Glasgow, or that Dundee can’t be an international games hub. We’re not just competing internally, either. That US bipartisan bill is designed to keep more of the screen sector in the States.
We’re competing with them, but we’re also competing with Finland, Estonia, the Middle East and India. They all recognise the value of the creative sector, making it an increasingly global competition.
Scotland is so well placed to take advantage of this. But if we don’t shout about it and get the right government support and infrastructure in place, we risk being left behind.
Music quiz show The Hit List, filmed in Glasgow, is another programme with the potential to keep running
Music quiz show The Hit List, filmed in Glasgow, is another programme with the potential to keep running
Katie: My final question: how important do you think financial literacy is for building a strong creative arts sector in Scotland?
Pamela: It’s incredibly important. According to a report by Creative UK, the creative industry faces four times higher barriers to funding than almost any other industry. That issue multiplies when you go outside London, and it multiplies further for women-led companies. The gap between founder-led, entrepreneurial creative businesses and traditional private equity funds or institutional lenders is huge. They just don’t speak the same language. A lot of what I’ve wanted to do has been around work with those fast-growing indies to help bridge that gap.
So part of it is education on the funder side regarding creative infrastructure and the value of IP. So much of the value in creative businesses is tied up in intellectual property, and companies need to understand the deals they are entering into so they aren’t signing over their IP to a private equity fund.
On the other side, there’s the investment readiness piece, because so many of the barriers stem simply from the fact that both sides aren’t speaking the same language.
swgroup.com/people/pamela-collie
Discover ICAS’ policy positions in relation to tax
Built with Shorthand