Franco-Nevada Reaches Settlement on Canadian Tax Disputes

Franco-Nevada Reaches Settlement on Canadian Tax Disputes

(in U.S. dollars unless otherwise noted)

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 ( Barbados ) Corporation and Franco-Nevada Mexico Corporation, S.A. de C.V. ("Franco-Nevada Barbados" and "Franco-Nevada Mexico", respectively) outside of Canada .

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 to Franco-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 of C$1.4 million in Canada 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 Franco-Nevada and its shareholders," said 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."

Advisors and Counsel

Osler , Hoskin & Harcourt LLP acted as legal counsel to Franco-Nevada.

Corporate Summary

Franco-Nevada Corporation is the leading gold-focused royalty and streaming company with the largest and most diversified portfolio of cash-flow producing assets. Its business model provides investors with gold price and exploration optionality while limiting exposure to cost inflation. Franco- Nevada uses its free cash flow to expand its portfolio and pay dividends. It trades under the symbol FNV on both the Toronto and New York stock exchanges. Franco- Nevada is the gold investment that works.

Cision View original content: https://www.prnewswire.com/news-releases/franco-nevada-reaches-settlement-on-canadian-tax-disputes-302554477.html

SOURCE Franco-Nevada Corporation

Cision View original content: http://www.newswire.ca/en/releases/archive/September2025/11/c9788.html

News Provided by Canada Newswire via QuoteMedia

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Franco-Nevada

Franco-Nevada

Franco-Nevada is a precious-metals-focused royalty and investment company. The company owns a diversified portfolio of precious metals and royalty streams, which is actively managed to generate the bulk of its revenue from gold, silver, and platinum. The company does not operate mines, develop projects, or conduct exploration. Franco-Nevada's short-term financial performance is linked to the price of commodities and the amount of production from its portfolio of producing assets. Its long-term performance is affected by the availability of exploration and development capital. The company holds a portfolio of assets, diversified by commodity, revenue type, and stage of a project, primarily located in the United States, Canada, and Australia.

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