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At issue is Cameco’s alleged practice of shifting profits to a Switzerland subsidiary where taxes are lower. And while the Cameco case has been going on for several years and though the CRA won the most recent round, the ruling is being appealed and observers say it is unclear who will come out on top.

“The CRA has had a lot of trouble proving some of these cases in court,” said Dennis Howlett, executive director of Canadians for Tax Fairness.

Observers say the practice of transfer pricing as a way to lower tax rates is widespread across corporate Canada, engaged in by many of the biggest and best known players across a swath of industries.

In Ottawa, the Minister of National Revenue is responsible for the CRA.

A spokesman for Revenue Minister Kerry-Lynne Findlay said in an emailed statement on Wednesday evening that Ms. Findlay “expects all taxpayers to respect the rules and pay their fair share. Abusive transfer pricing schemes are a very serious issue and this government’s record speaks for itself. Since 2006, CRA has made nearly $4.6B in transfer pricing adjustments.”

It’s not just Canada that is struggling with the problem. According to Mr. Howlett, what amounts to the transfer of profits to low tax jurisdictions is an issue across much of the developed world. The OECD is currently working on a plan that would see member jurisdictions update their rules in a bid to close loopholes.

Camecdo struck an agreement struck back in 1999 under which the subsidiary agreed to buy uranium at $10 a pound — the going rate in 1999. The subsidiary then sells the uranium at whatever is the world price.