You and qaz123 have done a good job trying to unravel what could be a fraud against GA taxpayers.
It appears, as of Jan 2021, that GA requires production companies that apply for a tax credit to submit to an audit conducted by a GA certified CPA, and that may resolve one of the many issues.
What triggered me, of course, was the potential fraud that arises downstream with a qualified holder who sells to an "unqualifed" GA taxpaying credit user. That also appears resolved by the current version of Title 48 which provides a credit buyer shall have only such rights and claims to use the credit that were available to seller at the time of the transfer. One would think that in practice that credit buyer would have to be a film production company.
The Audit Report you linked to dated January, 2020 may have prompted the current state of the law, it appears the final state of both was reached during the same time frame.
Yes, I too believe the 2020 audit by the state auditors prompted the new law.
However, as with the Election Integrity law passed last year, it doesn’t go far enough.
The new law only audits film programs up to a certain amount the first year, leaving a big wide window.
Projects over and above the limit are not audited the first year, which means all the crazy stuff can still get through by moving the questionable transactions to a project not eligible for audit.
But to the pubic at large, the government did “something” and therefore a lot of people walk away saying, “well, I guess the problem is solved.”