Cameco’s legal victory seen as rebuke to CRA’s costly pursuit – by Patrick Brethour (Globe and Mail – February 19, 2021)

For every day of his 10-year tenure at the head of Cameco Corp., Tim Gitzel has been saddled with a sprawling, costly and potentially ruinous tax dispute with the Canada Revenue Agency over how the uranium producer dealt with its overseas profits.

That dispute was punctuated, if not yet quite ended, on Thursday when the Supreme Court of Canada declined to hear the CRA’s appeal of lower-court decisions that had sided with the company.

The heart of the long-running dispute is transfer pricing, or how multinational companies such as Cameco determine what prices their subsidiaries charge each other for goods and services, with those decisions influencing how much tax is paid in various jurisdictions.

Tax lawyers say the Supreme Court decision is a clear repudiation of the CRA’s case, and what they see as an aggressive bid by the agency to rewrite transfer-price agreements that it deemed to be enabling tax avoidance.

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