The Supreme Court of Canada has turned down a request by the Canada Revenue Agency which sought to have the top court hear an appeal regarding Cameco Corp. and its use of a subsidiary in Switzerland to sell and trade its uranium.
As is custom, the court did not provide a reason for its decision to deny the request.
Saskatoon-based Cameco says the decision to deny the appeal request means its dispute with CRA for its 2003, 2005 and 2006 tax years is fully and finally resolved in its favour.
CRA had sought to appeal a Federal Court of Appeal decision to uphold a 2018 Tax Court of Canada ruling in Cameco’s favour regarding the uranium miner’s marketing and trading structure involving foreign subsidiaries.
The agency argued the structure was a sham established to avoid Canadian taxes, while Cameco maintained it was for legal and sound business practices.
Cameco says it expects to receive a refund of $5.5 million plus interest for amounts paid on previous reassessments issued by CRA for 2003, 2005 and 2006, as well as the $10.25 million in legal fees and up to $17.9 million for costs awarded by the Tax Court and the Court of Appeal in previous rulings.