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Passing the Cultural Test for Ireland’s Digital Games Tax Credit

Learn how to pass Ireland’s Digital Games Cultural Test to secure the 32% tax credit. Strategy, scoring, and tips to maximise your points and approval.

Chris Dowsett

Tax Incentives Manager - UK & IE

12/08/2025

10 minute read


Claiming under Ireland’s Digital Games Tax Credit scheme is an opportunity for Ireland’s games developers to recoup some of their costs of development, rewarding home-grown talent and incentivising further development.

However, to be able to take advantage of this tax credit, you must submit all the required documents, or risk losing your entitlement. Among these requirements is the Cultural Test application, sent to the Minister for Tourism, Culture, Arts, Gaeltacht, Sport and Media.

The Cultural Test isn't just a bureaucratic hurdle; it's the gateway to Ireland's generous digital games tax credit. Get it right, and you could save up to 32% in corporation tax. Get it wrong, and all that preparation goes to waste.

Let's break down exactly how this test works, why it matters so much, and most importantly, how to pass it with confidence.

Why the Cultural Test Matters More Than You Think

The Cultural Test is a pass-or-fail requirement that determines whether your game qualifies for Ireland's Digital Games Tax Credit scheme. There's no partial credit, no second chances without reapplying, and no workarounds.

The test evaluates whether your game has sufficient Irish or European cultural content to warrant public support through tax relief. It's not about making your game "Irish"; it's about demonstrating genuine connections to Irish or European culture, creativity, and talent.

The Numbers That Matter

The Cultural Test is scored across four sections with specific weightings:

  • Total points available: 35 points
  • Minimum required to pass: 14 points (40%)
  • Section-specific minimums: Sections A, B, and C each require at least one-third of their available points

Understanding the Cultural Test Structure

Before we dive into strategies, let's understand what you're working with. The test operates on a two-stage process:

Stage 1: Interim Cultural Certificate

Your Digital Games Development Company applies to the Minister for an 'Interim' cultural certificate. This allows you to claim relief annually as your game develops and remains valid for three years.

Stage 2: Final Cultural Certificate

Once development is complete, you must convert your interim certificate to final status after your game receives classification from the Irish Film Classifications Office (IFCO).

What You Need to Submit

Your application package must include:

  • Completed application form demonstrating eligibility
  • Game synopsis
  • Person Days Schedule (template provided)
  • Multiple compliance declarations
  • PEGI rating/IFCO certification (for final applications)
  • Commitment to include government acknowledgment in your game

Applications go to DigitalGames@tcagsm.gov.ie, with the Department working to issue certificates within 28 working days of receiving complete applications.

When applying for a final certificate, you’ll need your qualifying costs handy too.

Breaking Down the Four Sections

You need to demonstrate that you meet all of these requirements with evidence. It’s not enough to simply claim that your game is set in Ireland, for example. You must describe in your application exactly why you are claiming for the points you’re after.

Section A: Cultural Context (Up to 9 Points, Minimum 3)

This section evaluates how your game reflects Ireland or Europe as a cultural context.

Geographic and Character Elements (2 points maximum)

  • 1 point: Significant part set in Ireland, EEA state, or fictional European location
  • 1 point: Principal characters relate to Ireland or other European countries

Language Requirements (3 points maximum)

  • 2 points: Released in official EEA languages (Irish, English, French, etc.)
  • 1 point: Released in EEA minority languages

Cultural Inspiration (4 points maximum)

You can earn 2 points for demonstrating that your game was inspired by or based on any of the following:

  • Published European literary, cinematographic, or musical works
  • Irish or European historical and scientific heritage
  • Recognised Irish or European artistic works or movements
  • Elements of Irish or European culture, society, history, or identity
  • Irish or EEA non-fictional events or historical figures
  • Ireland/EEA cultural sensibilities (for children's games)

Plus another 2 points if your original concept was influenced by Irish or EEA culture, values, society, or identity.

Section B: Cultural Creativity (Up to 9 Points, Minimum 3)

This section focuses on innovation and the involvement of Irish or EEA talent in creative roles.

Creative Talent (2 points)

  • Underlying material written/created by Irish or EEA citizen/resident

Innovation Categories (3 points maximum)

You can gain one point for creativity or innovation for each of the following:

  • Game structure, narration, or gameplay
  • Graphics, animation, character design, or settings
  • Interactivity, user interface, or multiplayer functionality

Technical Innovation (2 points)

  • Technical innovation in the game or production tools/methodology

Music and Composition (2 points)

  • Music created by Irish/EEA composer AND original composition or new arrangement

Section C: Cultural Cluster (Up to 12 Points, Minimum 4)

This section evaluates your team's connection to Ireland and the EEA.

Development Location (2 points)

  • At least 50% of creative work conducted in Ireland or EEA

Key Positions (8 points maximum)

You’ll receive a point for each of the following roles that is held by an Irish or EEA national or resident.

  • Producer/Project Manager
  • Lead Writer
  • Technical Director
  • Lead Programmer
  • Creative Director
  • Lead Designer
  • Art Director
  • Lead Artist/Animator

Department Leadership (2 points for either)

  • Head of Department role held by Irish/EEA national in specified areas, OR
  • At least 50% of the development team consists of Irish/EEA nationals/residents

Section D: Concomitant Cultural Credit (Up to 5 Supplemental Points, No Minimum)

These bonus points reward broader social contributions. You’ll receive a point for each of the following:

  • The game is educational content for children (ages 0-12)
  • Themes of diversity/equality or demonstrated cultural diversity influence
  • Accessibility enhancements for people with disabilities
  • Environmental sustainability content or awareness
  • Mentoring/training opportunities for at least two Irish/EEA nationals during development via Screen Ireland’s Skills Development Plans

Creative Strategies to Hit the Threshold

Meeting the 14-point minimum doesn't require completely redesigning your game.

Here are practical approaches:

Low-Hanging Fruit

  • Add Irish/European voice actors: Easy way to score character points in Section A
  • Incorporate Irish music styles: Can contribute to both cultural context and creativity sections
  • Develop mentoring programs: Section D points while building local talent

Strategic Team Planning

  • Prioritise key roles for Irish/EEA team members: Focus on the eight positions that each award individual points
  • Consider co-development partnerships: Work with Irish studios to meet the 50% creative work threshold
  • Plan your department structure carefully: Ensure Irish/EEA nationals lead key departments

Content Integration Approaches

  • European architectural influences: Incorporate recognisable European design elements
  • Cultural references: Subtle nods to European literature, history, or artistic movements
  • Language strategy: Plan your initial release languages to maximise Section A points

An Example Application

Let's walk through how hypothetical Company A achieved 21 points – well above the 14-point minimum – without major content modifications:

Section A: Cultural Context (8 points)

  • Fictional European setting: 1 point
  • European characters: 1 point
  • English language release: 2 points
  • European architectural design and cultural elements: 2 points
  • EEA cultural influence on original concept: 2 points

Section B: Cultural Creativity (5 points)

  • Written by EEA citizen: 2 points
  • Creative character design: 1 point
  • Original music by EEA composer: 2 points

Section C: Cultural Cluster (7 points)

  • Creative work completed in Ireland: 2 points
  • Three key Irish roles (Producer, Director, Lead Programmer): 3 points
  • 50%+ Irish development team: 2 points

Section D: Concomitant Cultural Credit (1 point)

  • Mentored two Irish students in development stages: 1 point

 

Total: 21 points (7 points above the minimum requirement)

Common Pitfalls and How to Avoid Them

Underestimating Section Minimums

Remember: Sections A, B, and C each have minimum requirements. You can't compensate for a weak Section A by excelling in Section C. Plan to meet minimums across all required sections.

Last-Minute Applications

The cultural test should influence your development planning from day one, not be an afterthought. Team composition, creative decisions, and partnership arrangements all impact your score.

Furthermore, this is a requirement for making a claim, so you’ll want to submit your Cultural Test well in advance of making your claim to ensure you receive your certification in time.

Documentation Gaps

Points are only awarded if you can demonstrate your claims. Keep detailed records of creative processes, team compositions, and cultural influences throughout development, just in case you need to support your argument.

Planning Your Application Strategy

Making a successful claim means early planning and relying on your strengths where possible.

Step 1: Conduct an Early Assessment

Map out your potential points across all four sections before major creative decisions.

Step 2: Identify Your Strengths

Focus on maximising points in areas where you're naturally strong while ensuring you meet minimums in weaker sections.

Step 3: Build Strategic Partnerships

If you're lacking Irish/EEA talent or cultural connections, consider partnerships with Irish studios or cultural consultants.

Step 4: Document Everything

Maintain detailed records of all cultural influences, team contributions, and creative decisions that support your application.

Step 5: Review and Optimise

Before submitting, review your point calculation and look for opportunities to strengthen weak areas.

The Bottom Line

The Digital Games Cultural Test is an opportunity to demonstrate the genuine value your project brings to Irish and European digital culture. With proper planning and understanding of the scoring system, most projects can comfortably exceed the minimum requirements.

The key is treating the cultural test as an integral part of your project planning, not a last-minute compliance exercise. When you approach it strategically, you'll often find that meeting the requirements actually strengthens your game and development process.

Ready to navigate your Cultural Test application? We're here to help you assess your project's potential, identify optimisation opportunities, and ensure your application maximises every available point. Get in touch with our expert team to discuss how we can support your Digital Games Tax Credit journey.

Remember: This guide provides general information about the Digital Games Cultural Test. For personalised advice on your specific project and circumstances, consult with qualified tax relief specialists who can evaluate your unique situation.


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