Franco-Nevada settles its transfer-pricing dispute on the basis of no FAPI, and 30% mark-up for its management charges, re its Barbados and Mexican subsidiaries

Franco-Nevada has settled its appeal of CRA reassessments of its 2013 to 2019 taxation years in respect of its Barbados and Mexican subsidiaries on the basis that:

• it will not be required to recognize any FAPI in respect of those subsidiaries for those taxation years; and
• the service fees charged by Franco-Nevada for certain services provided to those subsidiaries will be adjusted to increase the markup applied to Franco-Nevada's cost of providing those services from the current range of 7% to 20%, to 30%.

Franco-Nevada will not be subject to tax on the additional service fees for those years due to the application of non-capital losses.

Neal Armstrong. Summary of 11 September 2025 Press Release of Franco-Nevada Corporation entitled “Franco-Nevada Reaches Settlement on Canadian Tax Disputes” under s. 247(2).