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Cameco wins landmark Canadian transfer pricing dispute


Area Tax


Article originally published in MNE Tax, October 2018.

Excerpt from "Cameco wins landmark Canadian transfer pricing dispute":

Cameco paid arm’s length prices on intercompany transfers of uranium to a wholly-owned Swiss subsidiary pursuant to long-term intercompany contracts, Canada’s Tax Court ruled on September 26, in a closely watched transfer pricing case.

Beginning in 1999, Cameco Corporation (Cameco), a Canadian corporation and the world’s largest publicly traded uranium company, entered into a series of long-term contracts for the sale of uranium to its wholly-owned Swiss subsidiary (Swissco).

Pricing under the long-term contracts was either fixed, base escalating, market-based, or a hybrid of base escalating and market-based, but in the latter three cases prices were only partially adjusted to reflect changes in the uranium spot price.

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