The Canada Revenue Agency (CRA) has filed an appeal in the Supreme Court of Canada seeking to overturn its June 26 loss in the Federal Court of Appeal in its transfer pricing dispute with Cameco.
Cameco received notice of the appeal on October 30, confirmed Cameco president and CEO, Tim Gitzel, in a statement.
“After two clear and decisive rulings in our favour from the Tax Court of Canada and the Federal Court of Appeal that confirmed we complied with both the letter and intent of the law, it is incredibly disheartening and unfair for our employees, communities and many other stakeholders to be once again thrown into uncertainty as a result of CRA’s actions,” Gitzel said.
The case involves the question of when Canada’s tax agency can exercise its power to recharacterize related party transactions under Canada’s transfer pricing laws.
The Canada Revenue Agency sought to apply those powers in a dispute over Cameco’s 2003, 2005, and 2006 tax bills, alleging that transactions between Cameco and its Swiss subsidiary constituted a “sham” arrangement and resulted in improper profit shifting out of Canada.
A detailed look at the case and the issues involved can be found at this link.
Be the first to comment