24. Income taxes

(a) Income tax expense

The income tax recorded in the consolidated statements of income (loss) for the years ended December 31, 2021 and 2020 is presented as follows:

	2021		2020
	$		$

Current income tax
Expense for the year ⁽ⁱ⁾	1,231		7,153
Current income tax expense	1,231		7,153

Deferred income tax (Note 26 (b)):
Origination and reversal of temporary differences	(8,259	)	(1,062	)
Impact of changes in tax rates	-		11
Change in unrecognized deductible temporary differences	20,050		6,570
Other	(67	)	(1,759	)

Deferred income tax expense	11,724		3,760

Income tax expense	12,955		10,913

(i) In 2020, the current income tax expense includes an amount of US$4.5 million ($5.8 million) resulting from the San Antonio stream transaction (paid in 2021).

The provision for income taxes presented in the consolidated statements of income (loss) differs from the amount that would arise using the statutory income tax rate applicable to income of the consolidated entities, as a result of the following:

	2021		2020
	$		$
(Loss) income before income taxes	(43,720	)	27,142
Income tax provision calculated using the combined Canadian federal
and provincial statutory income tax rate	(11,586	)	7,193
Increase (decrease) in income taxes resulting from:
Non-deductible expenses, net	908		(11	)
(Non-deductible) non-taxable portion of capital losses, net	(761	)	(1,893	)
Differences in foreign statutory tax rates	(3,898	)	(408	)
Changed in unrecognized deferred tax assets	20,050		6,570
Foreign withholding taxes	864		778
Deferred premium on flow-through shares	(1,847	)	-
Effect of flow-through shares renunciation	8,021		-
Tax rate changes of deferred income taxes	-		11
Other	1,204		(1,327	)

Total income tax expense	12,955		10,913

The 2021 and 2020 Canadian federal and provincial statutory income tax rate is 26.5%.

(b) Deferred income taxes

The components that give rise to deferred income tax assets and liabilities are as follows:

	December 31,		December 31,
	2021		2020
	$		$

Deferred tax assets:
Stream interests	30,100		34,278
Non-capital losses	7,663		8,195
Deferred and restricted share units	3,401		4,008
Share and debt issue expenses	2,935		4,562
	44,099		51,043
Deferred tax liabilities:
Royalty interests and exploration and evaluation assets	(102,782	)	(93,266	)
Investments	(8,077	)	(9,437	)
Convertible debentures	(1,173	)	(2,315	)
Other	(474	)	(454	)

	(112,506	)	(105,472	)

Deferred tax liability, net	(68,407	)	(54,429	)

Deferred tax assets and liabilities have been offset in the balance sheets where they relate to income taxes levied by the same taxation authority and the Company has the legal right and intent to offset.

The 2021 movement for deferred tax assets and deferred tax liabilities may be summarized as follows:

							Other
			Statement				comprehen-
	Dec. 31,		of inco-				sive income		Translation	Dec. 31,
	2020		me (loss)		Equity		(loss)		adjustments	2021
	$		$		$		$		$	$

Deferred tax assets:
Stream interests	34,278		(4,178	)	-		-		-	30,100
Non-capital losses	8,195		(532	)	-		-		-	7,663
Deferred and restricted share units	4,008		(328	)	(279	)	-		-	3,401
Share and debt issue expenses	4,562		(96	)	(1,531	)	-		-	2,935
Deferred tax liabilities:
Royalty interests and exploration
and evaluation assets	(93,266	)	(9,543	)			-		27	(102,782	)
Investments	(9,437	)	1,831		-		(471	)	-	(8,077	)
Convertible debentures	(2,315	)	1,142		-		-		-	(1,173	)
Other	(454	)	(20	)	-		-		-	(474	)
	(54,429	)	(11,724	)	(1,810	)	(471	)	27	(68,407	)

The 2020 movement for deferred tax assets and deferred tax liabilities may be summarized as follows:

						Other
			Statement			comprehen-		Benefit from
	Dec. 31,		of inco-			sive income		flow-through		Translation	Dec. 31,
	2019		me (loss)		Equity	(loss)		shares		adjustments	2020
	$		$		$	$		$		$	$

Deferred tax assets:
Stream interests	28,826		5,452		-	-		-		-	34,278
Non-capital losses	170		8,025		-	-		-		-	8,195
Deferred and restricted share units	2,865		435		708	-		-		-	4,008
Share and debt issue expenses	(113	)	(569	)	5,244	-		-		-	4,562
Deferred tax liabilities:
Royalty interests and exploration
and evaluation assets	(77,641	)	(16,204	)		388		66		125	(93,266	)
Investments	1,911		(1,613	)	-	(9,707	)	(28	)	-	(9,437	)
Convertible debentures	(3,632	)	1,317		-	-		-		-	(2,315	)
Other	149		(603	)	-	-		-		-	(454	)
	(47,465	)	(3,760	)	5,952	(9,319	)	38		125	(54,429	)

The aggregate amount of taxable temporary differences associated with investments in subsidiaries, for which deferred tax liabilities have not been recognized as at December 31, 2021, is $114.6 million ($110.8 million as at December 31, 2020). No deferred tax liabilities are recognized on the temporary differences associated with investments in subsidiaries because the Company controls the timing of reversal and it is not probable that they will reverse in the foreseeable future.

(d) Unrecognized deferred tax assets

As at December 31, 2021, the Company had temporary differences with a tax benefit of $79.5 million ($57.3 million as at December 31, 2020) which are not recognized as deferred tax assets. The Company recognizes the benefit of tax attributes only to the extent of anticipated future taxable income that can be reduced by these attributes.

	December 31,	December 31,
	2021	2020
	$	$

Non-capital losses carried forward	64,650	43,379
Mineral stream interests - Mexico	7,446	5,796
Unrealized losses on investments	3,598	6,529
Capital losses	2,127	-
Other	1,694	1,632
	79,515	57,336