Canada’s Federal Court of Appeal, on June 26, ruled in favor of Cameco Corporation in the transfer pricing case, Her Majesty the Queen. v. Cameco Corporation, 2020 FCA 112.
The Appeals ruling upholds the 2018 Tax Court of Canada’s decision, also in favor of Cameco.
The case concerns a transfer pricing challenge by the Canada Revenue Agency against Cameco in connection with the Canadian parent company’s transactions with a subsidiary located in Switzerland.
The Canada tax agency alleged that the structure involving the Swiss subsidiary resulted in improper “profit shifting” out of Canada and that transactions between Cameco and its Swiss subsidiary constituted a “sham” arrangement. The case involves the re-characterization provision contained in Canada’s transfer pricing legislation.
–– MNE Tax will be publishing an in-depth look at this case written by a tax expert shortly.
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