On September 26^th, 2018, the Tax Court of Canada (TCC) published its 297-page-long decision in Cameco Corporation v. The Queen, 2018 TCC 195. The case revolves around the allocation of profits between Cameco Canada, one of the world’s largest producers of uranium, and its Swiss uranium trading entity. The Canadian Revenue Agency (CRA) challenged the transfer pricing and put forward that the relevant transactions involving the Swiss entity either were a sham or should be re-characterized with an adjustment of the transactions’ transfer prices with the consequence that profits should be attributed to Cameco Canada. The TCC did not follow the argumentation of the CRA but decided in favor of the taxpayer Cameco Canada. In its decision, the TCC relied on Canada’s transfer pricing rules and concluded that none of the transactions or arrangements were a sham and that there was no evidence to suggest that the contracts did not reflect the parties’ true intentions (i. e. no re-characterization).This article gives an overview of the key issues of the case and analyzes the facts under the light of the latest OECD TPG from 2017, asking whether a different result may be justified under the curr...