Executive summary
On 26 June 2020, Canada’s Federal Court of Appeal (FCA) released its decision in the case of The Queen v. Cameco Corporation, 2020 FCA 112, an appeal of the September 2018 Tax Court of Canada (TCC) decision in Cameco Corporation v. The Queen, 2018 TCC 195. The FCA upheld the TCC’s decision in favor of the taxpayer, and in doing so set out a succinct interpretation of the transfer pricing recharacterization provisions in the Income Tax Act (the Act).
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