Supreme Court docket of Canada dismisses CRA leave application in tax dispute with Cameco

Cameco president and CEO Tim Gitzel is calling it one other win for the uranium mining company in a saga that “has long previous on a ways too long.”

The Supreme Court docket of Canada pushed apart the Canada Income Company’s application for leave to enchantment a decrease court docket determination that dominated in favour of Cameco in an ongoing tax dispute.

“We are overjoyed that the Supreme Court docket of Canada has rejected CRA’s enchantment ask,” Gitzel acknowledged Thursday in a press beginning.

The dispute targeted on Cameco’s marketing and trading building involving foreign subsidiaries and the linked transfer pricing methodology archaic for certain intercompany uranium sale and elevate agreements.

The agency contended it changed into as soon as a sham established to lead clear of Canadian taxes, whereas Cameco maintained it changed into as soon as for genuine and sound business practices.

In June 2020, the Federal Court docket of Allure upheld a 2018 ruling from the Tax Court docket of Canada that centred on Cameco’s spend of a subsidiary in Switzerland to sell and alternate its uranium.

The ruling covers Cameco’s 2003, 2005 and 2006 tax years.

Gitzel acknowledged the Saskatoon-basically basically based company has continuously followed the regulation.

“It has been incredibly disheartening for us, as a Canadian company, to contain an agency of our federal authorities continue to pursue a incorrect argument for 13 years, even after receiving two court docket choices fully in our favour during that time,” Gitzel acknowledged.

“In the interim, now we contain needed to navigate thru a duration of challenging international markets and the unparalleled financial upheaval of the COVID-19 pandemic with the uncertainty induced by this tax dispute very much impeding our ability to maneuver. To narrate it has been unfair to our employees and the many moderately loads of stakeholders who depend on our company will most certainly be a exact understatement.”

Cameco acknowledged it expects to receive a refund of $5.5 million plus interest on outdated assessments for these tax years.

The CRA continues to defend $785 million in money and credit letters from the company for moderately loads of tax years currently in dispute — 2007 thru 2014.

Gitzel acknowledged they think that wants to be returned to Cameco given the certain rulings from the courts.

“We are going to most certainly be asking CRA to unbiased derive the certain and decisive rulings the courts contain delivered and apply them to subsequent tax years in advise that we can point of interest on managing our business for the abet of all our stakeholders,” Gitzel acknowledged.

“If CRA feels the prison guidelines aren’t written the model they want, it’s certain they must assassinate the case to authorities to alternate these prison guidelines moving forward in keep of unfairly dragging Canadian businesses thru long and costly correct processes.”

The tax court docket has awarded Cameco $10.25 million for genuine prices incurred and as much as $17.9 million for disbursements.