[T]he employer resident in Canada, which carries on a business of operating a fleet of vessels providing transportation services, signed a contract for a Chinese manufacturer to construct vessels to be acquired by it, and sent two engineers to China for over 24 months to ensure compliance with plans and specifications. Their period of employment abroad is greater than 24 consecutive months.
After referring to the scope of qualifying activities in s. 122.3(1)(b), CRA stated:
[T]he employer would not be engaged in a qualifying activity because it carries on a marine transportation business and not any of the above.
As a result, the salaries paid to engineers dispatched to China would not qualify for the OETC.