The Candian Revenue Agency will appeal its Canada’s Tax Court loss in the Cameco transfer pricing case to the Federal Court of Appeal, according to an October 25 report in Mining.com
In a 286-page judgment, Canada’s Tax Court held that Cameco paid arm’s length prices on intercompany transfers of uranium to a wholly-owned Swiss subsidiary under long-term intercompany contracts. The court said the transactions were not a sham and did not violate the arm’s length standard contained in Canada’s domestic transfer pricing rules.
For MNE Tax coverage of the Tax Court ruling and the underlying dispute, see, Cameco wins landmark Canadian transfer pricing dispute by Kabir Jamal, Goodmans LLP, Toronto.
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