INCOME TAXES

12 Months Ended

Dec. 31, 2023

The effective tax rates for the years ended December 31, 2023 and 2022 were 23.9% and 187.3%, respectively.

Income tax expense consisted of the following components:


	Years ended December 31,
	2023		2022
Current income taxes:
Canadian current income taxes	$	3.6	$	1.6

Foreign current income taxes	48.3		76.0

	51.9		77.6
Deferred income taxes:


Foreign deferred income taxes - origination and reversal of temporary differences	(21.2)		0.5

	(21.2)		0.5

Total income tax expense	$	30.7	$	78.1

The Company is subject to income tax in several jurisdictions, at various tax rates. A number of factors other than the current year tax rates affect the relationship between the income or losses in a jurisdiction for financial accounting reporting purposes and the income tax provision required to be recognized for those same reporting purposes.

These factors are illustrated below on all of the consolidated earnings (loss) before income taxes after applying a tax rate of 26.5%, reflecting the combined Canadian statutory corporate income tax rate which applies to the Company as a legal entity for the years ended December 31, 2023 and December 31, 2022:


	Years ended December 31,
	2023		2022
Earnings before income taxes	$	128.2	$	41.7
Income tax provision - 26.5%	$	34.0	$	11.0
Increase (reduction) in income taxes resulting from:
Earnings in foreign jurisdictions subject to a different tax rate than 26.5%	(31.9)		(7.4)
Permanent items that are not included in income (losses) for tax purposes:
Non-deductible expenses	(0.9)		(3.3)
Income (losses) not recognized for tax purposes	(3.5)		1.0
Tax provisions not based on legal entity income or losses for the year:
Provincial mining duty tax	3.8		1.4
Non-resident withholding tax	5.5		15.8

Under (over) tax provisions	0.3		2.8



Other	0.3		0.8
Other adjustments:
Unrecognized recoveries in deferred tax provisions	21.4		46.7
Foreign exchange related to deferred income taxes	(2.2)		9.0
Taxes paid relating to sale of assets	4.1		—
Other	(0.2)		0.3
Total income tax expense	$	30.7	$	78.1

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


	Years ended December 31,
	2023		2022
Deferred income tax assets:
Exploration and evaluation assets	$	442.4	$	307.7


Asset retirement obligations	—		2.5
Côté Gold repurchase option	91.5		—
Other assets	43.8		34.3

	577.7		344.5
Deferred income tax liabilities:
Property, plant and equipment	(572.8)		(355.3)






Other liabilities	(5.6)		(11.8)
	(578.4)		(367.1)
Net deferred income tax liabilities	$	(0.7)	$	(22.6)


Classification:
Non-current assets	$	—	$	—
Non-current liabilities	(0.7)		(22.6)
	$	(0.7)	$	(22.6)

Income tax expense (recoveries) related to OCI consisted of the following components:


	Years ended December 31,
	2023		2022
Unrealized change in fair value of marketable securities	$	—	$	0.1

Hedges	(0.7)		(0.9)

Total income taxes related to OCI	$	(0.7)	$	(0.8)

Unrecognized Deferred Income Tax Assets

As at December 31, 2023, the Company did not recognize the benefit related to the following deferred income tax assets for the above related items in its consolidated financial statements, as management did not consider it probable that the Company would be able to realize these deferred income tax assets in the future.

Deferred income tax assets have not been recognized in respect of the following deductible temporary differences:


	Years ended December 31,
	2023		2022

Non-capital losses	$	1,099.1	$	1,186.5
Net capital losses	104.4		66.2
Exploration and evaluation assets	338.6		380.8
Deduction for future mining duty taxes	18.9		15.1

Asset retirement obligations	265.3		213.3
Other deductible temporary differences	0.1		13.0
	$	1,826.4	$	1,874.9

The net capital loss carry forwards are restricted in use against capital gains but may be carried forward indefinitely. The exploration and evaluation assets may be carried forward indefinitely. At December 31, 2023, the non-capital loss carry forwards expire as follows:


Expiry Date	2024		2025		2026		2027		2028+		No Expiry		Total



Total unrecognized losses	$	13.5	$	44.3	$	21.7	$	15.5	$	974.3	$	29.8	$	1,099.1

The Company has not recognized a deferred income tax liability on temporary differences of $527.0 million (December 31, 2022 - $593.6 million) related to investments in certain subsidiaries and joint ventures because the Company can control the reversal of the temporary differences and the temporary differences are not expected to reverse in the foreseeable future.

The Company designates all dividends paid to its shareholders to be eligible dividends.

The 2023 movement for net deferred income tax liabilities is summarized as follows:



	December 31, 2022		Discontinued Operations		Statements of earnings (loss)		OCI		December 31, 2023
Deferred income tax assets:
Exploration and evaluation assets	$	307.7	$	—	$	134.7	$	—	$	442.4


Asset retirement obligations	2.5		—		(2.5)		—		—
Côté Gold repurchase option	—		—		91.5		—		91.5
Other assets	34.3		—		8.8		0.7		43.8
Deferred income tax liabilities:

Property, plant and equipment	(355.3)		—		(217.5)		—		(572.8)






Other liabilities	(11.8)		—		6.2		—		(5.6)

	$	(22.6)	$	—	$	21.2	$	0.7	$	(0.7)

The 2022 movement for net deferred income tax liabilities is summarized as follows:



	December 31, 2021		Discontinued Operations		Statements of earnings (loss)		OCI		December 31, 2022
Deferred income tax assets:
Exploration and evaluation assets	$	—	$	—	$	307.7	$	—	$	307.7
Non-capital losses	210.4		(37.8)		(172.6)		—		—

Asset retirement obligations	1.7		—		0.8		—		2.5
Other assets	37.2		—		(0.7)		0.9		37.4
Deferred income tax liabilities:

Property, plant and equipment	(281.0)		66.1		(140.4)		—		(355.3)
Royalty interests	(0.4)		—		0.1		—		(0.3)


Marketable securities	—		—		0.1		(0.1)		—

Inventories and reserves	(7.4)		10.0		(5.7)		—		(3.1)
Other liabilities	(21.7)		—		10.2		—		(11.5)

	$	(61.2)	$	38.3	$	(0.5)	$	0.8	$	(22.6)

Global minimum top-up tax

The Company operates in France which has enacted legislation to implement the global minimum top-up tax with effect as of January 1, 2024. Canada has also proposed implementation of the global minimum top-up tax with effect as of January 1, 2024, however to-date Canada has only released draft legislation in that regard.

The Company also operates in Barbados for which draft legislation has been released to apply an effective tax rate of 15% through the imposition of a top-up tax, with effect January 1, 2024.

The Company does not expect to be subject to any material amounts of top-up tax for any of its entities for the foreseeable future.

The Company has applied a temporary mandatory relief from deferred tax accounting for any impacts of a top-up tax and will account for any such top-up tax as a current tax when incurred.

None of the Company’s operations would have been subject to a top-up tax if it had applied in 2023.

Excessive interest and financing expenses

With effect in 2024, Canada proposes to restrict the deductibility for income tax purposes of excessive interest and financing expenses (“EIFEL”). In light of (a) the significant tax pool balances available to the Company and (b) the carryforward deductibility of any such limitations in a given year, the EIFEL proposals are not expected to represent a tax cash exposure for the foreseeable future.