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Franco-Nevada Reaches Settlement on Canadian Tax Disputes

Franco-Nevada Reaches Settlement on Canadian Tax Disputes Canada NewsWire (in...

articleFranco-nevada CorporationSeptember 11, 20253/company/franco-nevada-corporation/news/franco-nevada-reaches-settlement-on-canadian-tax-disputes
Franco-Nevada Reaches Settlement on Canadian Tax Disputes

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[{"type":"text","content":"\n\n\n\n Franco-Nevada Reaches Settlement on Canadian Tax Disputes\n \n\n /* Style Definitions */\nspan.prnews_span\n{\nfont-size:8pt;\nfont-family:\"Arial\";\ncolor:black;\n}\na.prnews_a\n{\ncolor:blue;\n}\nli.prnews_li\n{\nfont-size:8pt;\nfont-family:\"Arial\";\ncolor:black;\n}\np.prnews_p\n{\nfont-size:0.62em;\nfont-family:\"Arial\";\ncolor:black;\nmargin:0in;\n}\n \n\n\n\n\n\n Canada NewsWire\n \n\n\n\n\n (in U.S. dollars unless otherwise noted)\n \n\n\n\n\n TORONTO\n \n\n ,\n \n\n Sept. 11, 2025\n \n\n /CNW/ - Franco-Nevada Corporation (\"Franco-Nevada\" or the \"Company\") is very pleased to announce that it has reached a settlement with the Canada Revenue Agency (\"CRA\") which provides for a final resolution of Franco-Nevada's tax dispute in connection with the reassessments under transfer pricing rules of the 2013 to 2019 taxation years (the \"Reassessments\") related to income generated by two of the Company's wholly-owned foreign subsidiaries, Franco-Nevada (\n \n Barbados\n \n ) Corporation and Franco-Nevada Mexico Corporation, S.A. de C.V. (\"Franco-Nevada Barbados\" and \"Franco-Nevada Mexico\", respectively) outside of\n \n Canada\n \n .\n \n\n\n Settlement Highlights\n \n\n\n\n The settlement will not require the payment of any tax in\n \n Canada\n \n on the foreign earnings of Franco-Nevada Barbados and Franco-Nevada Mexico for the 2013 to 2019 taxation years.\n \n\n 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 to Franco-Nevada's cost of providing those services from the current range of 7-20% to 30%.\n \n\n This additional service fee will result in Franco-Nevada being subjected to Canadian tax on additional income of\n \n C$1.4 million\n \n in\n \n Canada\n \n 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.\n \n\n 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.\n \n\n The settlement is not legally binding on the CRA for years after 2019, however, we believe the transfer...

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