02 October 2018 Tax Court of Canada finds for the taxpayer in Cameco transfer pricing case The Tax Court of Canada (TCC or the Court) released its decision in Cameco Corporation v The Queen, 2018 TCC 195 on September 26. The Court allowed the taxpayer’s appeal, concluding that none of the transactions, arrangements or events in issue was a sham, and reversed the Minister of National Revenue (the Minister)’s transfer pricing adjustments under section 247 of the Income Tax Act (Canada) (the Act) for each of the taxation years in question. In so concluding, the Court found that there was no evidence to suggest that the contracts entered into by the parties did not represent the parties’ true intentions. Document ID: 2018-1939 |
