Canada vs Cameco, November 2017, Pending case – C$2.2bn in taxes

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Several mining companies are beeing audited by the Canadian Revenue Agency for aggressive tax planning and tax evasion schemes. Among the high-profile companies that have filed pleadings with the Canadian Tax Court are Cameco, Silver Wheaton, Burlington Resources, Conoco Funding Company and Suncor Energy.

The CRA says, the companies inappropriately ran international transactions through subsidiary companies in low-tax foreign jurisdictions.

In the Cameco case the Revenue Agency has audited years 2003 to 2015 and challenged Cameco Canada’s arrangements with a Swiss subsidiary. Cameco sells uranium to its marketing subsidiary in Switzerland, which re-sells it to buyers, incurring less tax than the company would through its Canadian office.

The CRA position is that Cameco Canada was in fact carrying the uranium business – not Swiss Cameco subsidiary.

The total tax bill for the 13 years: $2.1-billion, plus interest and penalties.

Three tax years are currently being tried in the tax court, where a final decision is expected in late 2018 or early 2019

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