VGTC or R and D tax credit: which one for a game studio?

CIJV or CIR is never decided in one block: the video game tax credit (CIJV) funds the creation and development of a video game work approved by the CNC, while the research tax credit (CIR) targets genuine research and development work. You arbitrate expense by expense, and never count the same charge twice.

The video game tax credit is set out in article 220 terdecies of the French tax code (CGI). It covers the creation and development expenses of a video game work and equals 30 % of eligible expenses, up to a ceiling of 6 million euros per company and per financial year.

Two conditions shape eligibility. First, a minimum development cost of 100,000 euros: below that, the game does not open the right to the scheme. Second, obtaining CNC approval, granted in two stages (provisional approval at launch, then final approval), after a cultural test assessing the content of the work. The scheme applies to expenses incurred until 31 December 2031.

The CIJV logic is therefore that of a work: the focus is on the creation and development of the game, not on the scientific novelty of the techniques used.

The research tax credit, provided for in article 244 quater B of the CGI, funds research and development expenses in the tax sense: fundamental research, applied research and experimental development.

The logic here is entirely different. Writing code that is new to your studio is not enough: you must demonstrate genuine research and development, meaning an established state of the art, a real scientific or technical uncertainty, and the lifting of obstacles that existing knowledge did not allow you to overcome. A proprietary engine, an artificial intelligence component or a rendering algorithm that are truly novel may fall under this logic; routine game production does not.

This is the point I systematically stress in scoping meetings: the CIJV and the CIR do not combine on the same expenses. A single charge can never feed both credits.

That said, a single studio can fall under both logics on distinct expenses. A common pattern in our files: the creation and development of the game are carried by the CIJV, while a genuinely new technical component (an engine, a matchmaking system, an AI approach) is isolated and documented for the CIR. The underestimated risk lies exactly there: in trying to maximise, some studios slide the same expense into both bases. In a tax audit, that means a near-certain reassessment.

The arbitration is decided on three criteria: the real nature of the work, the available documentation, and the level of risk accepted in case of an audit.

Our take: for the vast majority of a game budget (game design, art, level design, integration, testing), the CIJV is the natural reflex, provided you aim for and obtain CNC approval. The CIR only makes sense on the fraction of work that genuinely clears the research bar: not code that is new to you, but code that is new to the state of the art.

Whatever credit you keep, it is the documentation that holds the file together in an audit.

• For the CIJV: file the provisional approval request at the right time, follow the cultural test, trace creation and development expenses per work.
• For the CIR: build a technical file from the start of the financial year (state of the art, identified obstacles, experimental approach, results), rather than reconstructing it afterwards.
• Keep a clear analytical breakdown that isolates, expense by expense, what belongs to the CIJV and what belongs to the CIR.
• Keep supporting records of time spent and salaries assigned to eligible work.
• Document the boundary between the two bases to prove the absence of double counting.

A studio is preparing a game whose budget far exceeds 100,000 euros. Most of the costs (art creation, gameplay, production) fall within the CIJV base after CNC approval. In parallel, the team develops a procedural generation technology that runs into a real technical obstacle. This fraction of expenses, isolated and documented separately, can be presented for the CIR, without ever being included in the CIJV base. Two credits, two watertight bases.

This boundary work is exactly what we frame with studio directors. If you are setting up your scheme, our dedicated video game studios sector page details how we support you, from the choice between CIJV and CIR through to securing the documentation. This article is informational; a decision specific to your studio requires reviewing your situation, your work and the rules in force.