Creative State 2020+ Submission to Victoria's consultation on - September 2019 - iGEA

Creative State 2020+ Submission to Victoria's consultation on - September 2019 - iGEA
Submission to Victoria’s
consultation on
Creative State

                       September 2019
                            Interactive Games &
 @igea    /   Entertainment Association
Creative State 2020+ Submission to Victoria's consultation on - September 2019 - iGEA
E x ecuti v e S u mma r y a n d
                                                     R e com m end a t io n s
Executive Summary and Recommendations

                                                     The Interactive Games & Entertainment              •V
                                                                                                          ictoria’s current policy settings for the
                                                     Association appreciates the opportunity             games industry are working. Building
                                                     to contribute to this important consultation        an industry takes years and it is vital
                                                     on Creative State 2020+. This submission            that existing support mechanisms
                                                     provides an overview of Victoria’s game             remain in place to support the long-term
                                                     development sector and reflects on                  success and sustainability of Victorian
                                                     what Victoria has been able to achieve,             games businesses.
                                                     from successful and growing games
                                                     businesses to the two globally renowned            •O
                                                                                                          f all of Australia’s jurisdictions, Victoria
                                                     events of Melbourne International Games             has an opportunity to turn its ambitious
                                                     Week and the Melbourne Esports Open.                but still maturing games industry into
                                                                                                         an Asia-Pacific equivalent of the kind of
                                                     Our paper highlights why there remains              industry that exists in the UK or Canada.
                                                     a vital need to continue investing in the           What’s needed is an expenditure-
                                                     games sector and the many diverse and               based incentive such as a rebate – an
                                                     unique benefits that the industry provides          initiative that is significant but proven,
                                                     to the state – from growth and foreign              necessary and transformative.
                                                     investment to productivity and jobs – while
                                                     highlighting some current challenges and           •T
                                                                                                          he process for developing Creative
                                                     risks.                                              State 2020+ can also look broadly at
                                                                                                         the range of alternative or additional
                                                     Our submission also seeks to illustrate             policies that have been successfully
                                                     a vision for what the games industry                adopted elsewhere in Australia and the
                                                     can achieve through the many practical              world. The submission outlines some
                                                     examples of countries and regions                   key support mechanisms that could
                                                     analogous to Victoria in population                 also be considered, including attraction
                                                     size and economic progress where                    funding to encourage other major studios
                                                     governments have worked closely with                to Australia and a payroll tax rebate to
                                                     industry to build, in many cases, billion-          encourage studios to hire and grow.
                                                     dollar industries that hire and upskill
                                                     thousands of workers.

                                                     The second half of our submission
                                                     provides our views on this consultation
                                                     holistically, including providing our
                                                     support for the guiding principles and our
                                                     perspectives on the discussion themes.
                                                     Our submission finally outlines our three
                                                     key messages for policymakers in the
                                                     context of Creative State 2020+:

                                 2      Submission to Victoria’s consultation on Creative State 2020+
Creative State 2020+ Submission to Victoria's consultation on - September 2019 - iGEA
I ntrod ucti on
The Interactive Games & Entertainment         Together with our fellow creative sectors,
Association (IGEA) is the peak industry       we would like to take this opportunity to
association representing the business and     applaud Victoria’s long-term focus on
public policy interests of Australian and     creativity, recognising that building a
New Zealand companies in the interactive      creative state also creates a state that
games industry. Our members develop,          has an ambitious economy, innovative
publish, market and distribute interactive    businesses and a talented workforce
games and entertainment content and           and communities. We are particularly
related hardware. We proudly represent        appreciative of the Minister for Creative
a number of influential Victorian-based       Industries Martin Foley MP, Creative
games businesses, including Australia’s       Victoria and Film Victoria for their
largest game studio Firemonkeys,              recognition of video games as both a
development industry leaders Big Ant          creative artform and business-minded
Studios and Wicked Witch, the successful      industry. Through Creative State 2016-20,
and celebrated Hipster Whale, the ‘AAA’       they have supported the game studios that

satellite studio Sledgehammer Games and       call the state home and have shared in the
of course Nintendo Australia which has its    celebration of our many successes. We
headquarters in Melbourne.                    appreciate the opportunity to participate in
                                              the Victorian Government’s consultation on
                                              Creative State 2020+ and are pleased to
                                              be able to provide this submission.

                          Florence by Mountains Studio includes loving nods to Melbourne

                                                Submission to Victoria’s consultation on Creative State 2020+   3
Creative State 2020+ Submission to Victoria's consultation on - September 2019 - iGEA
T he s tate of Vic t o r ia ’s
                                                    g am es s ect o r

                                                    More Australian game development                   •L
                                                                                                         eague of Geeks, a major Melbourne-
                                                    studios continue to call Victoria home than         based game development collective
                                                    any other state. These are studios who              whose meticulously maintained debut
                                                    are hiring and training game developers,            game Armello continues to strengthen its
                                                    producers and designers and creating                fan base year after year.
                                                    games that are enjoyed not only in
                                                    Australia, but (mostly) elsewhere around           • Mighty Games, another significant
                                                    the world. According to our research, there           Victorian independent game studio with
                                                    were 46 Victorian game studios in 2017,               a talent for designing and developing
                                                    located not only in Melbourne but also                creative and appealing social games like
                                                    in regional areas. Considering that our               Shooty Skies, which was downloaded 5
                                                    research only measured ASIC-registered                million times in its first few months.
                                                    businesses and relied upon voluntary
                                                    survey responses, it is likely that this figure    • Mountains Studio, whose first game
                                                    is conservative.                                      Florence, launched in 2018, won several
                                                                                                          international awards for Best Mobile
                                                    Victoria is home to some of Australia’s               Game, including at the Game Awards,
                                                    most significant and successful games                 Game Developers Choice Awards and
                                                    titles and studios and we would like to start         British Academy Games Awards.
                                                    our submission by highlighting just a few
                                                    of them:                                           • Opaque Media, an innovative studio that
                                                                                                          developed a Virtual Reality Earthlight
                                                      ig Ant Studios, a leader of Victoria’s
                                                    •B                                                    spacewalking simulator for NASA and
                                                     games sector and one of its most                     the Virtual Dementia Experience for
                                                                                                          Alzheimer’s Australia Victoria.
The state of Victoria’s games sector

                                                     influential studios which has created,
                                                     among many other titles, games with
                                                     distinctly Australian character like Rugby        • Paper House, whose first game
                                                     League Live 4, Cricket 19 and Big Bash               Paperbark, developed in partnership
                                                     Boom.                                                with League of Geeks, follows a wombat
                                                                                                          in a beautifully rendered Victorian bush,
                                                    • Firemonkeys, Australia’s largest game              deservedly winning awards and acclaim
                                                       studio, owned by the global video                  for its design and artistry.
                                                       games giant Electronic Arts (EA), which
                                                       continues to develop and support a              • Sledgehammer Games, the Australian
                                                       range of globally popular titles, including        satellite studio of the acclaimed
                                                       games for EA’s acclaimed The Sims and              developer of the ‘AAA’ Call of Duty
                                                       Need for Speed franchises.                         games, one of the greatest video games
                                                                                                          franchises of all time, and part of the
                                                    • Hipster Whale, one of Australia’s most             global video games giant Activision
                                                       successful game studios of the past                Blizzard.
                                                       decade, who have turned their success
                                                       with Crossy Road, which has been
                                                       played by over 200 million players, into
                                                       a collaboration with Disney and other
                                                       successful titles.

                                4      Submission to Victoria’s consultation on Creative State 2020+
Creative State 2020+ Submission to Victoria's consultation on - September 2019 - iGEA
• Tantalus, one of Victoria’s oldest game        celebration anywhere in the Asia-Pacific
   development studios with a 25-year             region, with its centrepiece event PAX
   history of working with publishers             Australia welcoming more attendees and
   around the world and honing their              hosting more panels in 2018 than ever
   specialist expertise in performing             in its history. In 2018 IGEA ran a booth
   licensed platform conversions for global       to collect stories on the power of games
   partners, including with Microsoft on their    for our Digital Australia 2020 research.
   acclaimed Age of Empires series.               We heard stories from many Victorians
                                                  (including young people from regional
• Tin Man Games, a major Melbourne-              Victoria who had travelled for hours to get
   based game studio that has published           there) as well as fellow Australians from
   over 35 titles, achieving particular           all states who told us about how important
   success and acclaim with their                 MIGW was to help them connect with the
   Gamebook Adventures series. They               industry and artform that they love.
   also published Miss Fisher and the
   Deadly Maze, bringing another beloved          Melbourne also hosted the inaugural
   Australian character to the interactive        Melbourne Esports Open (MEO) in 2018,
   screen and to new audiences in Australia       arguably the biggest esports festival in
   and abroad.                                    Asia-Pacific region, marrying Victoria’s
                                                  quadruple loves of creativity, sport, culture
• The Voxel Agents, a studio founded in          and entertainment. The first MEO pulled
   2009 that has produced internationally         in over 12,000 fans into Melbourne Park
   popular games played by millions of            and was watched by millions around the
   people and whose latest game, The              world while the second MEO fitting took
   Gardens Between, won Game of The               place during the consultation period.
   Year at the Australian Game Developers         Given the continued rise of esports and
   Awards award among other local and             the unprecedented popularity of gameplay
   global accolades.                              spectatorship in Australia and around the
                                                  world, whether it is watching international
• Torus Games, another longstanding              gaming competitions or online streamers
   Victoria studio that has operated for          showcasing indie games, it is clear how

                                                                                                                    The state of Victoria’s games sector
   25 years focusing on both original and         influential video games are as a cultural
   licensed titles and a string of games and      force.
   franchises that have sold in the millions.
                                                  Finally, our submission would like to
• Wicked Witch, a significant and influential    highlight the Australian Centre for the
   Victorian studio with a long history of        Moving Image (ACMI) in Melbourne as one
   success over almost two decades, from          of the best cultural institutions in the world
   original games like Puzzle Wiz to distinctly   that gives homage to video games and
   Australian rugby, AFL and cricket games.       is another example of Victoria’s special
   Wicked Witch is also working with              relationship with games. As an industry, we
   Microsoft on Age of Empires II.                are already in conversations with ACMI on
                                                  ways to collaborate ahead of its reopening
Of course, Victoria’s connection with             in 2020. The recognition of games in the
video games goes well beyond just its             Victorian Government’s creative industries
development industry and the state                strategy is justified, visible and – most
has had a major impact on connecting              importantly – working.
Australian and international game players
culturally. Melbourne International Games
Week (MIGW) remains the largest games

                                                    Submission to Victoria’s consultation on Creative State 2020+   5
Vi ctor i a’s g a me d e ve lo p me n t
                                                            i n d us tr y m a t t e r s
Victoria’s game development industry matters

                                                            While it is already well understood                   Based on our Digital Australia 2020
                                                            by Victoria, we would like to use this                research, just under two out of three
                                                            submission to again highlight the                     Victorians played video games in 2018,
                                                            economic, cultural and social importance              almost three quarters of Victorian game
                                                            and opportunities of video games as a                 players were adults and games were
                                                            creative sector that should be nurtured               roughly equally played by men and
                                                            and supported.                                        women alike. Mirroring national trends, 89
                                                                                                                  per cent of Victorian households had at
                                                            Australians and Victorians                            least one gaming device. The ability for
                                                            love video games                                      games to project Australian stories and
                                                                                                                  voices to audiences at home and abroad
                                                            Video games have amongst the largest                  are therefore profound from a cultural and
                                                            support base of any creative industry,                economic perspective, although given the
                                                            with well over 2 billion gamers in the world          fact that Australian games are only a small
                                                            including over a billion in our region alone.         drop in the global ocean, we are not yet
                                                            Australians spent over $4 billion on video            close to fully leveraging this opportunity.
                                                            games and games hardware in 2018, a 25
                                                            per cent increase from 2017. This means               Victorians care about
                                                            Australians spend more on games than                  making games
                                                            they spend on films, streaming services,
                                                            pay TV, music, books or likely any other              Victorians don’t just love to play games,
                                                            creative or entertainment activity.                   they also believe in the importance of
                                                                                                                  games and in the artistry and industry

                                                                                            Cricket 19 by Big Ant Studios, the official game of the 2019 Ashes

                                       6       Submission to Victoria’s consultation on Creative State 2020+
of making video games too. According           Game studios allow creative
to our research, two thirds of Victorians      people to express themselves
believe that making games in Australia
is important for the economy, and even         Perceptions that game developers are
more believe that the games industry is        exclusively software developers and

                                                                                                                 Victoria’s game development industry matters
important for Australia. Victorians have       engineers are untrue and thankfully
also recognised the importance of games        dated. While video games are of course
outside of pure entertainment, with a third    technology-driven and continue to draw
of Victorians having already used games        Victorians into the ICT sector, game
at work for learning, over half of Victorian   studios are also training up and giving
parents saying that their children have        opportunities to a diverse next generation
used games at school and almost a third        of Victorian creatives, from digital and
saying their children have learned some        visual artists to writers, actresses and
coding at school.                              actors, composers and musicians, sound
                                               engineers and directors.
According to the same research, a
significant number of Victorians also          Game businesses are therefore providing
said that they were interested in a career     increasingly important work opportunities
in games, had studied coding or had            to creative professionals in the wider film,
even tried making games themselves.            TV and print sectors that are experiencing
According to our analysis, Victoria has        limited growth by comparison. The
more universities and colleges teaching        games industry is also developing deep
tertiary-level courses in various aspects      synergies with Victoria’s vibrant post-
of game development than any other             production, digital and visual effects
jurisdiction, reflecting the strong interest   (PDV) sector. Based on conversations
among the next generation of Victoria’s        with our members, there has a been
workforce in this industry.                    a deepening of relationships between
                                               businesses across both sectors including
Game development is an                         increased collaboration on projects and
important creative output                      transferability of workers, particularly as
                                               games engines become more important to
Video games are an artform that is             animation and filmmaking. In the future we
arguably more unique, diverse and              expect our industries to draw even closer.
impactful than any other creative output.
Games create striking visuals like film or     Bridging the creative and
TV and deliver narratives like literature      technology industries
and theatre. They convey emotion through
sound like recorded and live music             The games sector has a unique position
and display colour and movement like           in the Australian economy in that video
dance and visual art. And unlike those         game businesses are often both creative
other artistic mediums, they are deeply        businesses as well as technology
interactive and therefore particularly         businesses and video game practitioners
compelling and engaging. Whether we are        often have skills that are highly sought-
talking about atmospheric and immersive        after in industries well beyond games.
platformers like The Gardens Between,          Video games are at their heart technology
moving and personal interactive stories        products and services and are often
like Florence, or gorgeously stylised          among the most complex, detailed and
games like Crossy Road, it’s clear that        interconnected kinds of software that exist.
Victorians are particularly creative and       While video games continue to be popular
talented auteurs in game design and            as entertainment for people of all ages
development.                                   across the world, games are also finding

                                                 Submission to Victoria’s consultation on Creative State 2020+   7
‘serious’ applications, including in the           As Creative State 2016-20 highlighted,
                                                            education, healthcare, defence, business,          more than 90 per cent of Victorian digital
                                                            research and community sectors.                    games are already developed for a global
                                                                                                               audience. Australian games are already
                                                            Melbourne Metro Trains’ Dumb Ways to               popular in English-speaking and European
Victoria’s game development industry matters

                                                            Die game, based on the viral public safety         countries and our proximity to Asia means
                                                            video, remains to this day one of the              that we are on the doorstep of the region
                                                            best examples of gamified government               of the world where digital games are most
                                                            messaging in the world. Showing a                  popular. Also, unlike many other kinds
                                                            different side of games, Victorian studio          of Australian exports, including other
                                                            Big Ant Studios has developed simulation           digital exports, individual games have the
                                                            software for law enforcement, while former         potential to provide a long revenue tail
                                                            Victorian studio Well Placed Cactus’s              and generate sustained wealth through
                                                            B2B capabilities were regarded so highly           ongoing content that capture and grow
                                                            that the studio was acquired by Deloitte.          player bases and leverage diverse income
                                                            Reflecting innovation like this, Australian        streams.
                                                            game businesses that specialise in
                                                            ‘gamification’ or ‘serious games’ are in           Contributing to Victoria’s
                                                            high demand. Game developers also                  economy and society
                                                            often have highly transferrable skills, while
                                                            practitioners of game engines and those            Wildly successful and globally popular
                                                            as the forefront of emerging technologies          Victorian video games are some of, if not
                                                            like AI and virtual, augmented and mixed           most of, Victoria’s most successful creative
                                                            reality are among the most in-demand               exports that have brought in significant
                                                            professionals in the entire technology             levels of investment, tax revenues and
                                                            industry.                                          jobs into the state. A typical 50-person
                                                                                                               studio might spend approximately $7
                                                            Video games are the ideal                          million each year on staffing, expenses,
                                                            creative export                                    investments and development costs. Many
                                                                                                               Victorian-made games are built on original
                                                            Games are a high potential export                  intellectual property, meaning that export
                                                            industry for Victoria given that they              profits flow through to proud Victorian
                                                            are increasingly digital and therefore             businesses who re-invest these profits into
                                                            exported instantaneously around the                building even more and better products
                                                            world without transportation costs or              to export. Victoria’s pool of (English-
                                                            significant environmental footprint. Unlike        speaking) talent is highly regarded and
                                                            many other kinds of Australian products            Victoria’s advantageous time zone also
                                                            that may only have viable or sustainable           makes our game development businesses
                                                            export markets in certain parts of the             ideal candidates for collaborative or
                                                            world, the global digital games market is          joint projects with overseas partners.
                                                            the entirety of the billions of game players       For example, the global positioning of
                                                            across six continents. The ability of video        Melbourne’s Sledgehammer Games
                                                            games to transcend language and cultural           studio helps it to contribute to a 24/7
                                                            barriers by focussing on interactive user          cycle of development on Call of Duty
                                                            engagement, visual communication,                  games. Australia’s small, but advanced
                                                            universal themes and fantasy worlds                and sheltered consumer market makes
                                                            gives our medium an automatic edge in              it an attractive testbed for trialling new
                                                            universal exportability over Australian            technologies including innovative gaming
                                                            films, TV programs and books.                      products and services, further enhancing
                                                                                                               the attractiveness of our businesses

                                       8       Submission to Victoria’s consultation on Creative State 2020+
C u r rent and f u t u re
c hal l eng es f o r Vic t o r ia
However, moving forward, Victoria’s game        around the world (which is discussed
development industry is not without its         further in this paper). There is a brain
challenges. Our 2017 industry survey            drain occurring where many of our most
tells us that despite the numerous success      talented and ambitious game developers
stories and undeniable talent in our            – meaning many of our most talented
industry, it remains small, employing just      and ambitious creatives and technology
928 workers in Australia with around half       practitioners – have left and are continuing
of that figure based in Victoria. This simply   to leave Victoria and Australia to use
is not reaching the potential that Australia    their talents. This also means Australia

                                                                                                                    Current and future challenges for Victoria
and Victoria can and should have the            is missing out on tens, if not hundreds of
capability to achieve. The preparation of       millions, in foreign investment as video
Creative State 2020+ must be considered         game publishers set up new studios or
in this context and we urge policymakers        ply capital into existing studios almost
to ask frank and bold questions about           everywhere around the world except for
what needs to be done to bridge the gap         Australia. By way of example, just one of
between where we are now and where              our members alone has invested well over
we want to be. We will also shortly be          $20 million into its studio here. The recent
conducting our next industry survey and         Interactive Aotearoa report developed
look forward to sharing and discussing the      by the New Zealand Game Developers
results with the Victorian Government.          Association, which we were a research
                                                partner of, noted that the emergence of
As we outlined in our Building a thriving       significant new studios in the country
game development industry paper that            had slowed in recent years.1 We worry
we released in December 2018, Australia’s       that Australia and Victoria has been
game development industry is being              experiencing the same and if so, growth
outpaced year-on-year by countries all
                                                1   NZGDA, Interactive Aotearoa, 2019, p. 8

                               Paperbark by Paper House, set in the beautiful Victorian bush

                                                    Submission to Victoria’s consultation on Creative State 2020+   9
needs to be reignited lest the industry drift       particularly if the forward-looking policy
                                                          into stagnation.                                    recommendations from Interactive
                                                                                                              Aotearoa are implemented.
                                                          While these challenges to Australia’s
                                                          game development industry are holistic,             Our key overarching message for the
                                                          Victoria is arguably most at risk given the         development of Creative State 2020+ is for
                                                          relative size and position of the state’s           Victoria to focus on keeping its competitive
                                                          games sector. Victoria is also facing the           edge and to be intrepid and strategic
                                                          added challenge of the fact that other              in how it designs its policy framework
                                                          states are increasingly appreciating                for the next critical few years so that it
                                                          and understanding the opportunities                 can continue to charge its high-potential
                                                          from supporting game development                    games industry in Melbourne and across
                                                          and taking action. In recent months,                regional areas. The relentless growth of
                                                          Western Australia has launched a games              the video games market, worth $4 billion
                                                          fund while Queensland has expanded                  in Australia and $200 billion globally, as
Current and future challenges for Victoria

                                                          its sqhub working space to the Gold                 well as the continued growth of game
                                                          Coast. During the Creative State 2020+              development as a global industry where
                                                          consultation process alone, South                   there are likely tens of billions of dollars
                                                          Australia has announced a new $300,000              of development work underway at any
                                                          games innovation fund as well as coup               one time, means that there is no creative
                                                          in bringing a new Sony Interactive                  industry worth investing in more than game
                                                          Entertainment engineering office to                 development. What this means is that the
                                                          Adelaide.                                           Victorian Government can realistically
                                                                                                              aim to grow the state’s independent
                                                          Policies like these are helping to                  studios into self-sustaining, successful
                                                          accelerate the growth of the games sector           and renowned small and medium sized
                                                          outside of Victoria, with many of Australia’s       businesses, focussed on original and
                                                          largest and most successful studios like            valuable intellectual property, and for the
                                                          Mighty Kingdom, Gameloft, Wargaming,                industry leaders to grow to companies
                                                          SMG Studio, Blowfish Studios and Team               that employ hundreds and eventually
                                                          Cherry thriving and growing in Sydney,              thousands like they do overseas. What
                                                          Brisbane and Adelaide. Furthermore, the             we should aim to achieve is realistic and
                                                          relative strength of New Zealand’s game             achievable because it already exists
                                                          development industry, arguably Victoria’s           elsewhere, as is discussed in the following
                                                          most significant rival in the oceanic               section.
                                                          region, will provide a further challenge,

                                                                                     Necrobarista by Route 59, an upcoming game set in a Melbourne café

                                  10         Submission to Victoria’s consultation on Creative State 2020+
A l ong- ter m g o a l f o r Vic t o r ia ’s
g am e d ev el o p me n t in d u st r y
We now turn to the heights that Victoria                    United Kingdom
should aspire to. While Victoria continues
to grow and remains a leading driver of                     The successes of Canada are likewise
Australia’s broader game development                        echoed in the UK. The UK game
sector, both have yet to reach their                        development industry achieved revenues
potential and continue to be outperformed                   of AUD $3.23 billion in 2018, having almost
by almost every other developed economy                     tripled in value from 2013 figures, and
around the world with a games sector.                       employed 16,532 workers, up from 9,400
When Victoria and other Australian                          in 2013.2 As of 2018 there were 2,261
governments consider what can be                            active games companies in the UK, two of
achieved within our shores, these other                     which being Rockstar North and Rockstar
countries shine a light for us, but industries              Games which developed Grand Theft
of their scale cannot be achieved                           Auto V, the most financially successful
without investment and thoughtful,                          entertainment product of all time.
long-term planning and support. As
we will identify later in this paper – the                  United States
common denominator for this success are
government tax incentives to encourage                      Giving a detailed analysis of the US
investment, jobs and game production.                       industry in this submission would not
                                                            provide a helpful comparison to Australia,
Canada                                                      with the US industry dwarfing even the
                                                            most significant countries in this list. There
Despite roughly similar populations                         are a number of reasons why the US
and economic size, there is sadly no                        games industry has the scale that it does,
defensible comparison between the                           but like most other countries in this list, tax
scale of Victoria or Australia’s industry                   incentives are a common denominator with
and Canada’s industry. While Australian                     close to half of all US states having them.
game developers achieved revenues of                        For example, even a state like Georgia,

                                                                                                                                A long-term goal for Victoria’s
$118.5 million and employed 928 workers                     which is far from the most significant                               game development industry
in 2017, Canadian game developers                           US state for video game development
achieved revenues of AUD $3.5 billion                       but is supported by an attractive game
and employed 21,700 workers.1 There are                     development tax credit, has 160 gaming
3,500 workers in one studio alone (Ubisoft                  companies.3 One studio in Georgia alone,
Montreal – just one of five studios that                    Hi-Rez, employs over 450 programmers,
Ubisoft has in Canada), well over three                     digital artists and designers – or around
times more than in the entire Australian                    the same number of video game workers
industry. Although it is well known and                     as the whole of Victoria.
often joked about within the industry that
American and Canadian studios currently
employ many Australians and benefit
from their talent and creativity, the loss of
this talent from our shores is no laughing
                                                            2   TIGA, Making Games in the UK Today, 2019

1 ESA Canada, 6 Essential facts about the Canadian video   3
   game industry, 2018                                         digital-entertainment

                                                                Submission to Victoria’s consultation on Creative State 2020+   11
France                                                      the region and this paper has included
                                                                                                           it as a marker of what is happening all
                                               France is another successful environment                    across Europe, from Spain and Portugal to
                                               for video game developers, where the                        Romania and the Czech Republic, where
                                               industry achieved revenues of AUD $8                        innovative and successful game studios
                                               billion and employed over 5,000 people in                   are taking root, often hastened through tax
                                               2018, making it France’s second largest                     incentives to encourage investment and
                                               cultural industry behind books.4 The                        entrepreneurship.
                                               French video game business Ubisoft is
                                               one of the largest video game companies                     New Zealand
                                               in the world and the publishers of globally
                                               successful games like the Tom Clancy                        While New Zealand’s industry does not
                                               and Assassin’s Creed franchises, although                   have the scale of most of the economies
                                               many of these are made in the many                          listed above, it still outperforms Australia
                                               studios they have established around the                    on many metrics. New Zealand’s game
                                               world.                                                      development industry achieved revenues
                                                                                                           of AUD $135 million in 20187 – greater than
                                               Finland                                                     the entirety of Australia’s industry – despite
                                                                                                           having a significantly smaller population
                                               People familiar with the Finnish game                       than even Victoria. The industry across
                                               development industry will not be surprised                  the Tasman also employed 550 workers,
                                               that the sector achieved revenues of AUD                    approximately three times as many per
                                               $3.44 billion and employed 3,200 workers                    capita as Australia. Like Australia, New
                                               in 2018.5 What is more surprising is that                   Zealand game developers have a strong
                                               they have achieved this with a population                   export focus and in 2018, Auckland-based
                                               less than the population of Victoria. The                   studio Grinding Gear Games was acquired
                                               Finnish Government’s support for the                        by Tencent for over NZD $100 million in
                                               industry has helped to grow companies                       one of the country’s largest ever deals not
                                               like Rovio and Supercell that have created                  only in games, but in the whole technology
                                               some of the most internationally popular                    sector.8
                                               and successful mobile games of the
                                               decade.                                                     Similar to Australia, New Zealand’s
                                                                                                           game industry has largely operated with
                                               Poland                                                      limited government support compared
A long-term goal for Victoria’s

                                                                                                           to our respective film and TV industries.
 game development industry

                                               The total value of the Polish game                          We are already aware of Victorian
                                               development industry reached AUD $837                       game developers who have moved to
                                               million in 2018.6 While total employment                    New Zealand and should the country
                                               numbers are unclear, there are understood                   adopt even some of its policies from the
                                               to be around 400 active studios operating                   Interactive Aotearoa report, noting that its
                                               in the country. The Polish game studio CD                   Government wrote the report’s foreword,
                                               Projekt created The Witcher, based on a                     the gap between our industries is likely to
                                               Polish novel and regarded as one of the                     increase even further.
                                               greatest game series of all time, and is
                                               working on Cyberpunk 2077, potentially
                                               the most anticipated game of 2020.
                                               Poland is not even particularly unique in


                                               5 NeoGames Finland, The Finnish Games Industry Report
                                                  2018, 2019, p. 10-11
                                                                                                           7   NZGDA, p. 10
                                               6 Research and Markets, Poland Animation, VFX & Games
                                                  Industry: Strategies, Trends & Opportunities, 2019       8   NZGDA, p. 17

               12                 Submission to Victoria’s consultation on Creative State 2020+
T he Creati v e S t a t e 2 0 2 0 +
a s a hol i s ti c f r a me w o r k

                                                                                                                   The Creative State 2020+ as
Before our analysis of specific policy          the technology industry – including

                                                                                                                      a holistic framework
recommendations to support the video            the video games industry – and young
games industry, we have reviewed and are        people in regional Victoria with a focus
wholly supportive of both the overarching       on Indigenous communities should be
guiding principles and discussion themes        supported and celebrated.
for the Creative State 2020+ consultation.
We have tried to incorporate these              We similarly support the proposed
throughout our submission but have              whole of state focus for Creative State
provided some specific further comments         2020+. Providing creative employment
below.                                          opportunities to Victorians outside of
                                                metropolitan areas is vitally important not
Guiding principles                              only for the vibrancy and sustainability
                                                of those communities but for Victoria’s
We support the proposed guiding                 creative industries themselves. A holistic
principles that will help to shape Victoria’s   strategy will help creative young Victorians
next creative industries strategy. We           to find self-actualisation no matter where
particularly support deep and wide              they are, while creative organisations can
consultations with Victoria’s First Peoples     find the best talent across the state to fill
to ensure that their perspectives and           key roles and find the next generation
priorities are central to the drafting and      of content creators and leaders. Game
direction of Creative State 2020+. Video        development is unique in that it can occur
games provide a wonderful opportunity           in any location that has a strong internet
to preserve and tell Indigenous stories         capability and often remotely through
and organisations like Luggarrah that           teams that may have members located
are seeking to foster links between             hundreds of kilometres away from each

                                    Hyper Jam by Bit Dragon was supported by Film Victoria

                                                   Submission to Victoria’s consultation on Creative State 2020+    13
other. It has often been celebrated how            We look forward to working more closely
                                           Crossy Road was developed partly in                with Creative Victoria to further track,
                                           regional Victoria, and policies should             encourage and celebrate diversity
                                           ensure that game developers in regional            reflected in games. Finally, we would
                                           Victoria are given every chance to recreate        support policies that help to provide
The Creative State 2020+ as

                                           that success.                                      Victorians with even greater access to
                                                                                              programs that teach game development
   a holistic framework

                                           Finally, we also support a whole of                and design, such as through collaborative
                                           ecosystem approach and Creative State              initiatives between the government,
                                           2020+ should focus on recognising both             educational institutions and industry that
                                           the increasingly interconnected and                could potentially be considered.
                                           decreasingly ‘siloed’ nature of creative
                                           industries, as well as the importance of           Building sustainability must also be a
                                           continually building links between various         priority for Victoria’s creative industries and
                                           creative industries as the edges between           the video games sector has a particularly
                                           artforms and forms of entertainment blur.          promising potential to succeed. Wildly
                                           The strategy should consider how to                successful and globally popular Victorian
                                           improve the way that creative practitioners        video games are some of, if not most of,
                                           find opportunities to work with one                Victoria’s most successful creative exports
                                           another, support each other, achieve               that have brought in significant levels of
                                           common objectives and, if possible,                investment, tax revenues and jobs into the
                                           build transferable skills. For video game          state. Given that more than 90 per cent
                                           companies, this would lead to greater              of Victorian digital games are developed
                                           dialogue and collaboration with the film           for a global audience, the opportunities
                                           and TV sectors, publishing, music and              for digital import revenue and foreign
                                           visual arts in particular. To quote from the       investments for the coming decade must
                                           Guiding Principles for Creative State 2020,        not be wasted.
                                           this is how Victoria can “create a whole
                                           that is stronger than the sum of its parts”.       The size and ongoing growth of the
                                                                                              Australian and international video
                                           Discussion themes                                  games market means that the Victorian
                                                                                              Government can realistically aim to
                                           Equality of access and diversity at                grow the state’s emerging independent
                                           all levels are key priorities for the video        studios into self-sustaining, successful
                                           games industry. The diversity of video             and renowned small and medium
                                           games as an artform and their digital form         sized businesses, focussed on original
                                           means that there is nowhere in the state           intellectual property and commercial
                                           where video games cannot be enjoyed                partnerships, and for the industry leaders
                                           and given the growth of the mobile games           to grow to companies that take up whole
                                           sector, thousands of games including               buildings and rejuvenate precincts. While
                                           many Australian-made games have no                 existing policies like grants have helped
                                           cost barrier to play. We also believe              Victoria’s industry become what it is today,
                                           video games are particularly advantaged            they often provide little support to the
                                           in their ability to tell diverse Australian        larger studios that the eco-system needs
                                           stories – such as Victorian-made games             to hire workers, engage small studios
                                           that have culturally-diverse characters like       for support, attract foreign investment
                                           Florence or explore LGBTQIA+ issues like           and raise the industry’s profile and
                                           Australian Game Developer Award winner             attractiveness internationally. This is
                                           That Boy Is a Monstr.                              where an expenditure-based incentive,
                                                                                              discussed later in this submission,
                                                                                              becomes essential.

             14               Submission to Victoria’s consultation on Creative State 2020+
This submission has already discussed the global focus of Australian-made games as an
export product, games as an intersection of creativity and technology and the massive
local and global market of game players. Therefore, it is no surprise that we wholly support
the three remaining discussion themes of engaging globally, technology and its impacts
and growing audience and markets. On the last point, we note the commentary on the
consultation website that “there are too few occasions … where a new digital game finds
its biggest audience”. While we would argue that Victorian-made games have achieved a
greater audience and market than any other creative output from the state, we do agree
that more should be done to support local studios market their games and find channels to
players so that the industry can realise its full potential.

S upp or ti ng e xist in g g a me s
p ol i ci es b ey o n d 2 0 2 0 +

                                                                                                                   Supporting existing games
None of the diverse and wildly successful       and business development support to

                                                                                                                     policies beyond 2020+
video games industries that we’ve               the next generation of game developers
already discussed in this paper were built      among other creatives. We wholeheartedly
overnight. Countries like Canada and            support the continuation of these
the UK have slowly but surely built their       programs.
billion-dollar industries that employ many
thousands of high paying workers through        However, one of the key reasons for
a farsighted vision and commitment to a         Victoria’s dynamic and forward-looking
range of long-term policies. This is the        games industry – apart from the talent and
trajectory that Victoria is moving towards      creativity of Victorians themselves – is the
and there is no doubt that Creative State       support that the Victorian Government has
2016-20 has been achieving results              provided to help promising projects get
by supporting creative Victorian game           off the ground and for studios to establish,
developers do what they strive to do and        grow and find success. In particular, the
helping them to participate, engage, grow       Assigned Production Investment –
and achieve success.                            Games and Games Release programs
                                                have been pivotal to Victoria’s reputation
We believe there are significant merits         and legacy in leading Australia’s game
to the current approach, articulated in         development industry. The continuation
Creative State 2016-20 of supporting            of the programs past 2020 as industry
the game development industry through           investment is vital to the long-term growth
initiatives that support different segments     and sustainability of Victoria’s game
and levels of the sector. For example,          development sector, particularly at a time
the Creators Fund provides a means              when other states are recognising the
for independent creatives including             benefits of supporting games and are
burgeoning game developers to focus             competing with Victoria to land projects
on projects and gain the experience             and studios. Based on our conversations
to bring these projects into fruition and       with the industry, the scope and design of
into the next stage of their careers.           these funds are still working well and some
Foundry658 serves a similar part of the         have told us how important funds like
creative sector by providing seed funding       these have been to their success, allowing

                                                   Submission to Victoria’s consultation on Creative State 2020+   15
them to not only transform ideas into                 Government-industry collaboration that
                                         successfully shipped games, but to give               have provided so many Victorian game
                                         them a leg up to attract private investment           developers exposure to both public
                                         and enterprise loans, thus giving these               audiences as well as publishers and
                                         funds a type of ‘multiplier effect’ well              investors – exactly the kind of benefit that
                                         beyond their face value. We also believe              Creative State 2020+ should continue to
                                         the funds are being administered                      cultivate. We are proud to be members of
                                         particularly well by Film Victoria, who               the MIGW Steering Committee and hope
                                         continue to show a determination for the              to see the state’s involvement in the week
                                         industry to succeed.                                  and commitment to investing in its success
                                                                                               continue for many years to come.
                                         Likewise, the Games Company
                                         Placement program helps studios and                   Finally, we recognise the support that
                                         talent find and support each other and                Creative Victoria in particular has provided
                                         plays a vital role in the policy eco-system.          to the state’s game developers through
                                         We would also urge consideration of an                trade missions to help them show their
                                         expansion of this program to better link              wonderful games to the wider world. These
                                         industry, games colleges and students,                include recent missions to the Game
                                         similar to what is being trialled in other            Developers Conference (GDC) in San
                                         states. In the next section we recommend              Francisco and Gamescom in Germany. We
Supporting existing games

                                         a new expenditure-based incentive that                have heard from our members and other
  policies beyond 2020+

                                         could have a traineeship component                    Victorian developers how important trade
                                         attached.                                             missions have been to showcase their
                                                                                               games to consumers, but particularly to
                                         Melbourne International Games Week                    industry and how they have helped them
                                         has grown from strength to strength                   find publishers, investors and clients.
                                         since its start and Victoria’s support for            Despite the increasingly diverse ways in
                                         Game Connect Asia Pacific (GCAP) and                  which games businesses around the world
                                         PAX Australia has been central to this.               are now connecting with one another,
                                         MIGW brings a vibrancy to Victoria and                physical trade shows are often still where
                                         particularly Melbourne’s creative sector              deals are made and relationships forged.
                                         that has an ongoing influence extending               We urge Creative Victoria to continue this
                                         well beyond the week and beyond even                  support and work closely with Austrade
                                         video games. Creative Victoria’s Pax                  and industry to maximise the opportunities
                                         Rising Grants is an ideal example of                  for the local industry abroad.

                                                                                Fly as a bird in the stunning game Feather by Samurai Punk

           16               Submission to Victoria’s consultation on Creative State 2020+
T he cas e for a n e w
e x pend i ture - b a se d in c e n t ive

                                                                                                                 expenditure-based incentive
In preparing Creative State 2020+, the         One of the goals that Australia (and
Victorian Government is surely seeking         Victoria) must adopt is to increase the

                                                                                                                     The case for a new
the answer one question above all others       number of game development companies
about its video games sector: how do they      with 50+ workers, which we just don’t
now take it to the next level?                 have enough of and which are often the
                                               least supported. These larger studios
The answer, we believe, is simple and          are vital to the ecosystem as they often
is the reason why Australia and Victoria       provide the lion’s share of the industry’s
lags behind almost all other developed         employment opportunities, can support a
regions with their games sector by such        variety of projects and can collaborate with
a significant margin. Coincidentally, the      smaller studios. Clusters of larger studios
answer is also why Victoria and Australia      also help to create an attractive eco-
have been able to become global leaders        system, with many talented foreign and
in the adjacent PDV sector.                    expatriate Australian game developers
                                               (and particularly those with families) often
The answer is the establishment of an          reluctant to come to Victoria because
expenditure-base incentive such as a           of a perceived lack of ‘safety net’ job
percentage offset, credit, refund or rebate    opportunities. Clusters of larger studios
for game development similar to Australia’s    also help to increase competition for talent
30 per cent PDV offset for film (uplifted by   and increase overall salaries, and while we
an additional 10 per cent state incentive      acknowledge this can lead to difficulties
in some jurisdictions). An expenditure-        obtaining high-demand talent in the short
based incentive has worked to encourage        term, particularly for smaller studios, over
investment in game development                 the longer term it will lead to a much larger
everywhere around the world it has been        and more successful and sustainable
implemented in, and it has worked here         workforce and industry.
to build up Australia and Victoria’s PDV
sector in a relatively short period of time.   While Australia has wonderful examples
As a policy solution, it has proven time and   of independent, homegrown 50+ worker
time again to work – and it’s needed.          studios, such as Mighty Kingdom in
                                               South Australia that has scaled up
Objective and rationale                        significantly over the past two years, they
                                               are unfortunately still few and far between.
As outlined in our policy paper, Building      An expenditure-based incentive would
a thriving game development industry,          give our 10-30 person studios in Victoria
percentage-based expenditure incentives        that develop high quality games every
work because they complete the missing         opportunity to scale up into larger studios.
piece of the policy framework. While the       It would also create the right environment
existing grant schemes help enterprising       to turn existing studios into investment
developers turn into studios, and emerging     opportunities and trigger the establishment
studios into growing small businesses,         or acquisition of studios by global
expenditure-based incentives help small-       publishers, who are vital to the industry.
to-medium sized studios grow into industry
leaders while simultaneously attracting        Australia’s three largest studios
the largest game developers in the world       Firemonkeys, Wargaming and Gameloft,
to either invest heavily to grow existing      who were all either newly established or
studios or set up brand new studios of         acquired studios, have together brought
their own here.                                a pipeline of work, jobs and millions
                                                 Submission to Victoria’s consultation on Creative State 2020+    17
in investment with them and it is no               publishers, including the parent publishers
                                           coincidence that they also happen to               of some IGEA members, actively and
                                           be the three largest studios in Australia.         seriously scoping opportunities to set
                                           However, these larger studios are currently        up studios in Victoria or elsewhere in
                                           experiencing a range of challenges –               Australia. While our talent and a low dollar
                                           including higher development costs                 are keeping Australia in the game, our
expenditure-based incentive

                                           compared to overseas territories and               worry is that a lack of the same kind of
                                           difficulties finding talent at home – and          expenditure-based incentives that exist
                                           it cannot be taken for granted that in the         in the US, Canada, UK and Europe will
    The case for a new

                                           future they will continue to grow or even          again mean that those studios are instead
                                           stay in Australia at all in the long run.          established in those countries that already
                                                                                              have an embarrassing number of studios.
                                           Impact and benefits                                And unlike the fleeting international
                                                                                              footloose film and TV productions that are
                                           An expenditure-based incentive would               receiving significant portions of Victoria
                                           help turn Victoria into an affordable and          and Australia’s screen industry incentives,
                                           cost-effective place to do business and            these game studios will be invested in
                                           allow Victorian studios to compete on a            for the long term, establishing a footprint
                                           more level playing field. Every year there         via bricks and mortar studios, thereby
                                           are tens of billions of dollars of game            attracting other studios and talent to
                                           development investment being spent on              Victoria.
                                           projects, contracts and studios everywhere
                                           else around the world where conditions are         The fact that these other regions continue
                                           more attractive, and it is time that we give       to implement their expenditure-based
                                           our studios the ability to compete based           incentives year after year, and subject
                                           on their talents and creativity – because          them to exhaustive analysis, shows that
                                           they will win.                                     they work. For example, research identified
                                                                                              that across the UK in 2016, £78 million of
                                           A percentage-based model works                     tax offsets helped generated £390 million
                                           because unlike a contestable grant (which          in game development expenditure.1 It
                                           predominantly supports studios in their            also provided £294 million in Gross Value
                                           initial growth stages for a limited period of      Added and directly supported 4,640
                                           time) it reduces costs, leads to sustainable       full-time jobs.2 All of this benefits the state
                                           growth, promotes healthy risk-taking and           through economic growth – through the
                                           attracts commitment from private investors         games sector and flow-on effects on other
                                           over the long term. This has a number              industries – and increased tax revenue.
                                           of flow-on effects, including supporting           Analysis showed that the same £78 million
                                           Australian studios to create and leverage          in offsets helped to generate £156 million
                                           original intellectual property and make            in tax revenues through the video games
                                           them attractive providers of commission-           sector.3 Analysis of France’s incentive
                                           based and ‘fee-for-service’ development            likewise identified similar results, with each
                                           work to the global industry.                       €1 of support providing €8 of additional
                                                                                              investment and €1.80 of additional taxation
                                           It will also reduce the cost to global game        revenue.4
                                           publishers of locating game production
                                           activity in Australia, encouraging them to
                                           create substantial studios here that have
                                                                                              1 British Film Institute, Screen Business: How screen sector
                                           the creative and financial freedom to              tax reliefs power economic growth across the UK, October
                                           develop their own projects and contribute          screen-business-full-report-2018-10-08.pdf, p. 90
                                           to or even lead ‘AAA’ projects. These
                                                                                              2   British Film Institute, p. 77
                                           are not just hypothetical opportunities.
                                                                                              3   British Film Institute, p. 89
                                           As Creative Victoria and Invest Victoria
                                                                                              4 NZGDA, p. 31, citing Deutscher Games Fonds, Ernst &
                                           already know, there are currently global           Young analysis of Fonds d’Aide au Jeu Vidéo for Game, the
                                                                                              German Games Industry Association, 2018

                   18         Submission to Victoria’s consultation on Creative State 2020+
What would an expenditure-
based incentive look like?
Offsets and credits                             requirements, type of expenditure
around the world                                covered, minimum expenditure thresholds,
                                                maximum rebate available and other
To show what an expenditure-based               criteria. Many of these measures also exist
incentive could look like, the below            alongside separate grant-based incentives
table provides examples of just some            and many regions have multiple layers
of the offsets, credits or rebates              of incentives, such as in Canada and the
currently available around the world.           UK which has both federal and provincial/
Please note that the table is indicative        country incentives, and in the European

                                                                                                                   What would an expenditure-based
only and individual incentives may              Union which has EU and national (and
differ significantly in terms of eligibility    sometimes regional) incentives.

                                                                                                                         incentive look like?
Country, state or province (alphabetical)	Per cent of eligible production / labour
                                           costs refunded

British Columbia (Canada)                      17.5 per cent

Colorado (US)                                  20 per cent

France                                         30 per cent

Georgia (US)                                   20 per cent

Louisiana (US)                                 15-20 per cent

Ontario (Canada)                               35 per cent

Manitoba (Canada)                              35-40 per cent

Nevada (US)                                    15-25 per cent

New Jersey (US)                                30-35 per cent

New Mexico (US)                                25 per cent

Nova Scotia (Canada)                           25 – 50 per cent

Poland                                         19 per cent (proposed)

Prince Edward Island (Canada)                  25 per cent

Quebec (Canada)                                30 per cent

Singapore                                      40 per cent

Tennessee (US)                                 25 per cent

Texas (US)                                     22.5 per cent

United Kingdom                                 20 per cent

                                                   Submission to Victoria’s consultation on Creative State 2020+   19
Recommendation                                     Designing an incentive

                                               While it would undoubtedly be a significant        As part of this investigation, we note that a
                                               policy, a percentage-based expenditure             percentage-based expenditure incentive
                                               incentive is necessary if Victoria is              can be designed strategically and flexibly
                                               committed to moving its sector from a              to ensure support is deployed efficiently
                                               creative and ambitious, but undersized             and to address budgetary constraints
                                               ecosystem of largely small and medium              and specific policy priorities. Examples
                                               sized studios, to one that hires thousands,        include:
                                               attracts tens or hundreds of millions in
                                               investment and work and competes for               • Capping the rebate, with the French tax
                                               attention globally. It is therefore the one           credit capped at £6 million for instance
                                               key policy that we recommend must be
                                               seriously considered for implementation as         • Scaling or ‘stepping’ the rebate
                                               a part of Creative State 2020+.                       depending on budget, such as in
What would an expenditure-based

                                                                                                     Germany where the rebate is set at 50
                                               We note that one of the most significant              per cent for smaller projects and 25 per
                                               challenges for Victoria’s games industry              cent for larger projects
      incentive look like?

                                               and policymakers is the lack of support
                                               currently available at the federal level.          • Providing qualified rebate levels, such
                                               We note that unlike Canada and the                    as in Nova Scotia where developers are
                                               US, where screen incentives are heavily               eligible for the lesser of a 50 per cent
                                               weighted towards provincial/state                     rebate for labour expenditure or a 25 per
                                               policies, Australian screen policies have             cent rebate for total expenditure
                                               traditionally followed a complementary
                                               national model that emphasises federal             • Different rebate levels depending on the
                                               grants and offsets, with state-based grants           level of investment in the state, such as
                                               and offsets often in a supporting role.               in Manitoba which pays a higher rebate if
                                               For example, the Australian Government                more than a quarter of salaries are paid
                                               provides a 30 per cent PDV offsets with               to state residents
                                               South Australia, Queensland and most
                                                                                                  • Specific eligibility criteria for larger game
                                               recently New South Wales now offering an
                                                                                                     studios, such as in Ontario where special
                                               additional 10 per cent ‘top-up’ to create 40
                                                                                                     rules apply to large multinational-owned
                                               per cent incentives for PDV work in those
                                                                                                     studios to encourage them into the
                                               IGEA has called on the Australian
                                                                                                  • Increased rebate for production in
                                               Government to adopt a similar 30 per
                                                                                                     regional areas, with Nevada for instance
                                               cent offset for game development and
                                                                                                     offering an additional 5 per cent bonus
                                               we will continue to advocate on behalf of
                                                                                                     for production in a rural county
                                               the industry every day until there is one.
                                               However, Victoria must urgently consider           • Lower threshold for expenditure in
                                               whether it can afford to wait for federal             regional areas, such as Tennessee’s
                                               action, or whether it is timely to move               policy of a reduced minimum spend for
                                               forward and proactively introduce its own             music scoring work outside of the capital
                                               expenditure-based incentive in the 10-30
                                               per cent range either in anticipation of a         • The inclusion of a cultural threshold for
                                               federal offset or in lieu of one. We therefore        eligibility to ensure there is a sufficient
                                               call on the Victorian Government to                   Australian connection, such as the UK’s
                                               investigate such an incentive as part of its          cultural test which measures, personnel,
                                               preparation of Creative State 2020+.                  facilities, cultural contribution and

                    20            Submission to Victoria’s consultation on Creative State 2020+
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