On 13 December, Wheaton Precious Metals (WPM) announced it had reached a ‘principled settlement’ for its tax dispute with the Canada Revenue Agency (CRA). Whereas the CRA had been seeking at least US$265m from WPM in taxes, penalties and interest in relation to its reassessment for the 2005–10 tax years with subsequent years left open to similar re-assessment, under the terms of the settlement WPM will actually pay the CRA cash taxes of US$5m for the 2011–17 tax years, US$15m in deferred tax and US$3–4m in interest. More importantly, the settlement creates a framework for both WPM and the CRA to assess tax in future years whereby foreign income on earnings generated by WPM’s international subsidiaries will not be subject to tax in Canada.
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