Subsection 125.5(1) - Definitions
Eligible production corporation
Administrative Policy
10 November 2014 Memorandum 2014-0532801I7 - film or video production services tax credit
two separate tests
In agreeing that the two branches of the "eligible production corporation" test are distinct, the Directorate stated:
whether the production corporation provides services in respect of an accredited corporation, or whether it contracts directly with the copyright owner, is not relevant to the first branch of the test (i.e.,…the "primarily business" test). These facts are relevant in the second branch of the test (i.e., … the copyright ownership test) or the definition of "accredited production" in subsection 125.5(1)… .