You've stated it exactly correctly, and this has been true for some time.
I happen to know, because I've certainly been copied on the correspondence, that it's one of the reasons that the collecting societies in Europe have been complaining rather bitterly to the chief negotiator in the Canada-Europe trade talks: directors in Europe are disadvantaged by the fact that in Canada there is not sufficient clarity around directors' copyright claims to enable the directors' rights collective in Canada to collect—