Franco-Nevada Reaches Settlement on Canadian Tax Disputes
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Settlement Highlights
- The settlement will not require the payment of any tax in
Canada on the foreign earnings of Franco-Nevada Barbados and Franco-Nevada Mexico for the 2013 to 2019 taxation years. - The service fee charged by
Franco-Nevada for certain services provided to Franco-Nevada Barbados and Franco-Nevada Mexico will be adjusted to increase the mark-up applied toFranco-Nevada's cost of providing those services from the current range of 7-20% to 30%. - This additional service fee will result in
Franco-Nevada being subjected to Canadian tax on additional income ofC$1.4 million inCanada for the 2013 to 2019 taxation years. After the application of non-capital losses,Franco-Nevada does not anticipate any additional cash taxes will arise in respect of these years as a result of the settlement. - Transfer pricing penalties reflected in the Reassessments will be reversed. The interest charges reflected in the Reassessments will be reduced and adjusted consequentially to the adjustments described above.
- The settlement is not legally binding on the CRA for years after 2019, however, we believe the transfer pricing principles established by the settlement will apply to years after 2019, provided there are no material changes to the facts or law.
"We are pleased to reach this settlement with the CRA and believe it is a great outcome for
Advisors and Counsel
Corporate Summary
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