Franco-Nevada Resolves Tax Dispute with Canada Revenue Agency
TORONTO,Sept. 11, 2025 /PRNewswire/ – Franco-Nevada Corporation announced today it has reached a settlement with the Canada Revenue Agency (CRA), fully resolving a tax dispute stemming from reassessments related to transfer pricing rules for the 2013 to 2019 taxation years. The dispute concerned income generated by franco-Nevada’s wholly-owned foreign subsidiaries, Franco-Nevada Barbados Corporation and Franco-Nevada Mexico Corporation, S.A. de C.V. (“Franco-Nevada Barbados” and “Franco-Nevada Mexico,” respectively).
Key terms of the settlement include:
* No canadian tax will be levied on the foreign earnings of Franco-Nevada Barbados and Franco-Nevada Mexico for the 2013-2019 period.
* The service fee charged by Franco-Nevada for services provided to its Barbados and Mexico subsidiaries will be adjusted, increasing the mark-up from the current 7-20% range to 30%.
* This adjustment will result in Franco-Nevada being subject to Canadian tax on an additional C$1.4 million in income for the 2013-2019 taxation years. However, the company anticipates no additional cash taxes will be due due to the application of existing non-capital losses.
* Transfer pricing penalties initially assessed in the Reassessments will be reversed, and associated interest charges will be reduced accordingly.
* While not legally binding beyond 2019, Franco-Nevada believes the established transfer pricing principles will likely apply to future years, barring important changes in facts or legislation.
“We are pleased to reach this settlement with the CRA and believe it is a great outcome for Franco-Nevada and its shareholders,” stated Paul Brink,President & CEO of Franco-Nevada. “This settlement provides greater investment certainty for our global growth ambitions and puts the tax dispute behind us. We can now continue to focus on adding high-quality, long-life assets to our diverse portfolio as we have done over the last 18 months with approximately $3 billion of transactions being completed.”
Osler, Hoskin & Harcourt LLP served as legal counsel to Franco-Nevada throughout the settlement process.
Franco-Nevada Corporation is a leading gold-focused royalty and streaming company, boasting the largest and most diversified portfolio of cash-flow producing assets. The company’s business model offers investors exposure to gold price increases and exploration potential while mitigating cost inflation risks. Franco-Nevada utilizes its free cash flow to expand its asset portfolio and distribute dividends,and its shares trade on the Toronto and New York stock exchanges under the symbol FNV.
SOURCE Franco-Nevada Corporation
