Before employees go abroad to perform under the contract, they must work in Quebec to prepare and ship the equipment needed for the work to be performed overseas. Are they eligible for the OETC while they are still on Canadian soil and performing preparatory work under that contract? In its summary, CRA indicated, likely yes, and in the body stated:
The "all or substantially all" test is generally considered to have been met if 90% of the employment duties were performed outside Canada. … For example, if the qualifying period is 14 continuous months, and assuming that the employment duties are performed consistently over the period, the employee would not normally be expected to spend more than 1.4 months (10% of 14) in Canada performing the duties of employment that would otherwise qualify for the OETC.