Yes, that's generally right. There are a few exceptions to the EIFEL rule. There is one for a Canadian-controlled private company that has less than $50 million of taxable capital employed in Canada, so that would exempt most small and medium-sized Canadian controlled private corporations.
There's also a separate exemption that could apply to larger corporations that have activities only in Canada. It looks at who the shareholders are, who are the related people receiving interest payments and where the business is. If that company has no material foreign investments and no significant foreign shareholders or non-arm's length people who they're paying interest to, then that exemption could apply to a larger CCPC that can't meet the $50-million threshold.