Income Tax Act — I-3.3 125.4
axable Canadian corporation, to the extent that the amount paid is attributable to and does not exceed the salary or wages of the other corporation’s employees for personally rendering services for the production of the property, (iii) another taxable Canadian corporation all the issued and outstanding shares of the capital stock of which (except directors’ qualifying shares) belong to an individual and the activities of which consist principally of the provision of the individual’s services, to the extent that the amount paid is attributable to services rendered personally by the individual for the production of the property, or (iv) a partnership that is carrying on business in Canada, to the extent that the amount paid (A) is attributable to services personally rendered by an individual who is a member of the partnership for the production of the property, or (B) is attributable to and does not exceed the salary or wages of the partnership’s employees for personally rendering services for the production of the property, and (c) where (i) the corporation is a subsidiary wholly-owned corporation of another taxable Canadian corporation (in this section referred to as the “parent”), and (ii) the corporation and the parent have agreed that this paragraph apply in respect of the production, the reimbursement made by the corporation in the year, or within 60 days after the end of the year, of an expenditure that was incurred by the parent in a particular taxation year of the parent in respect of that production and that would be included in the labour expenditure of the corporation in respect of the property for the particular taxation year because of paragraph (a) or (b) if (iii) the corporation had had such a particular taxation year, and (iv) the expenditure were incurred by the corporation for the same purpose as it was by the parent and were paid at the same time and to the same person or partnership as it was by the parent. ( dépense de main-d’oeuvre ) production commencement time , in respect of a Canadian film or video production, means the earlier of (a) the time at which principal photography of the production begins, and (b) the latest of (i) the time at which a qualified corporation that has an interest in, or for civil law a right in, the production, or the parent of the corporation, first makes an expenditure for salary or wages or other remuneration for activities, of scriptwriters, that are directly attributable to the development by the corporation of script material of the production, (ii) the time at which the corporation or the parent of the corporation acquires a property, on which the production is based, that is a published literary work, screenplay, play, personal history or all or part of the script material of the production, and (iii) two years before the date on which principal photography of the production begins. ( début de la production ) qualified corporation for a taxation year means a corporation that is throughout the year a prescribed taxable Canadian corporation the activities of which in the year are primarily the carrying on through a permanent establishment (as defined by regulation) in Canada of a business that is a Canadian film or video production business. ( société admissible ) qualified labour expenditure , of a corporation for a taxation year in respect of a Canadian film or video production, means the lesser of (a) the amount, if any, by which (i) the total of (A) the labour expenditure of the corporation for the year in respect of the production, and (B) the amount by which the total of all amounts each of which is the labour expenditure of the corporation for a preceding taxation year in respect of the production exceeds the total of all amounts each of which is a qualified labour expenditure of the corporation in respect of the production for a preceding taxation year before the end of which the principal filming or taping of the production began exceeds (ii) where the corporation