The usual argument is Halloween against Christmas, and it has a title that makes the case for both. The film is about one holiday discovering the other: a town that lives for Halloween finds Christmas, falls for it and tries to run it.
That makes Christmas the subject of the plot rather than its backdrop, which scores well on plot dependency even though much of the film looks nothing like Christmas. Iconography is where it gets interesting: presents, a tree, snow and a Santa figure are all there, just not always in the form you would expect.
UK searches for it peak in October rather than December, which settles which holiday the public files it under. The rubric asks something else: how much Christmas is in it, and whether that is enough to count.