The dismissal means that a dispute regarding the 2003, 2005 and 2006 tax years is “fully and finally resolved in Cameco’s favour”, the company said.
Cameco also expects to receive CAD10.25m in legal fees and up to CAD17.9m in disbursements for costs awarded in previous rulings.
Cameco president and chief executive officer Tim Gitzel said the ruling was another win for the uranium mining company in a saga that “has gone on far too long.”
“We are pleased that the Supreme Court of Canada has rejected CRA’s appeal request,” Mr Gitzel said Thursday in a statement.
The long-running dispute focused on Cameco’s marketing and trading structure involving foreign subsidiaries and the related transfer pricing methodology used for certain intercompany uranium sale and purchase agreements.
The agency contended it was a system established to avoid Canadian taxes, while Cameco maintained it was for legal and sound business practices.
In June 2020, the Federal Court of Appeal upheld a 2018 ruling from the Tax Court of Canada that centred on Cameco’s use of a subsidiary in Switzerland to sell and trade its uranium.
Cameco said the ruling shows that the methods were “in full compliance with Canadian law for the tax years in question”.
