Canada vs Cameco Corp., February 2021, Supreme Court, Case No 39368.

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Cameco, together with its subsidiaries, is a large uranium producer and supplier of the services that convert one form of uranium into another form. Cameco had uranium mines in Saskatchewan and uranium refining and processing (conversion) facilities in Ontario. Cameco also had subsidiaries in the United States that owned uranium mines in the United States.

The Canadian Revenue Agency found that transactions between Cameco Corp and the Swiss subsidiary constituted a sham arrangement resulting in improper profit shifting. Hence, a tax assessment was issued for FY 2003, 2005, and 2006.

Cameco disagreed with the Agency and brought the case to the Canadian Tax Court.

In 2018 the Tax Court ruled in favor of Cameco and dismissed the assessment.

This decision was appealed by the tax authorities to the Federal Court of Appeal.

The Federal Court of Appeal in 2020 dismissed the appeal and also ruled in favor of Cameco

A application for leave to appeal from the judgment of the Federal Court of Appeal was then brought to the Canadian Supreme Court by the tax authorities.

The application for leave to appeal was dismissed by the Supreme Court.

 

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