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Agriculture

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The Agricultural Clean Technology Program will provide financial assistance to farmers and agri-businesses to help them reduce greenhouse gas (GHG) emissions.

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Cannabis

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Real Estate And Construction

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Rental Property Owners And Occupiers
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Real Estate Service Providers
Your company plays a key role in the success of landlords, investors and owners, but who is doing the same for you?

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Energy and natural resources

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Mining
There’s no business quite like mining. It’s volatile, risky and complex – but the potential pay-off is huge. You’re not afraid of a challenge: the key is finding the right balance between risk and reward. Whether you’re a junior prospector, a senior producer, or somewhere in between, we’ll work with you to explore, discover and extract value at every stage of the mining process.
Oil & gas
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Financial Services

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Manufacturing & distribution

Canadian manufacturers seeking to grow their businesses must address common issues, including limited access to finance, high raw material costs, inflexible...

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Private equity

To acquire high-quality assets in today’s unprecedented competitive global market, private equity firms and their portfolio companies must be increasingly...

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Professional services

Professional services firms face a dual challenge: anticipating and managing change not only for your clients, but also for your business. In today’s...

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Public companies

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Private business

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Power & Utilities

At Grant Thornton, we have the real-world experience and knowledge that can help you in considering all of your strategic alternatives. Whether it be managing...

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Tax and transfer pricing

Pricing considerations for Canadian-headquartered mining companies

06 Aug 20212 min read

As a mining company, setting up your headquarters in Canada, while conducting the rest of your mining operations in other jurisdictions, simply makes good business sense. After all, Canada is a leader in the mining sector, with plenty of capital, industry expertise and favorable tax incentives. However, mining companies with this structure can face some hefty taxation headaches without careful planning.

A robust transfer pricing framework is often essential for Canada-headquartered companies with mining operations overseas. Not only can such a framework allow you to reduce or potentially avoid non-compliance tax penalties from the CRA, but it also offers a host of benefits, from effective tax rate management to tax-efficient cash repatriation.

In this article, we highlight transfer pricing considerations around:

Internal and external financing, such as debt financing and streaming transactions, in compliance with Canadian transfer pricing legislation
Centralized marketing functions—specifically, the differences between a marketing agent and marketing support services from a transfer pricing and compensation perspective
Centralized procurement hubs—that is, the importance of setting up a cost-based or value-based compensation amount that reflects the functions performed, assets used, and risks assumed by the entity
Centralized R&D functions that compensate the Canadian company a cost-based or value-based amount that reflects the functions performed, assets used, and risks assumed in the context of the development, enhancement, maintenance, protection and exploitation (DEMPE) of the multinational enterprises’ intangibles.

There are many opportunities for Canadian-headquartered mining companies to establish a transfer pricing framework that both minimizes transfer pricing risks and achieves efficiencies across multiple jurisdictions.