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INCOME TAX | 12 Months Ended
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Dec. 31, 2024
INCOME TAX |
INCOME TAX | 24. INCOME TAX ​
| (a) | Reconciliation of Effective Tax Rate
​ Income tax expense differs from the amount that would be computed by applying the applicable Canadian statutory income tax rate to income before income taxes. The significant reasons for the differences are as follows: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | Years ended December 31,
​ | ​ | ​ | 2024 $ |  | ​ | 2023 $
Net income (loss) before tax | ​ | ​ | 212,209 | ​ | ​ | (11,051)
Statutory tax rate | ​ | ​ | 27.0% | ​ | ​ | 27.0%
Anticipated income tax expense (recovery) at statutory rates | ​ | ​ | 57,296 | ​ | ​ | (2,984)
(Deductible) non-deductible expenditures | ​ | ​ | (4,863) | ​ | ​ | 2,443
Differences between Canadian and foreign tax rates | ​ | ​ | 7,762 | ​ | ​ | (729)
Changes in estimate | ​ | ​ | 9,721 | ​ | ​ | 7,419
Inflation adjustment | ​ | ​ | (68,886) | ​ | ​ | (63,095)
Impact of foreign exchange | ​ | ​ | 40,652 | ​ | ​ | 70,014
Change in deferred tax assets not recognized | ​ | ​ | 12,443 | ​ | ​ | 11,489
Mining taxes | ​ | ​ | 5,316 | ​ | ​ | 2,714
Withholding taxes | ​ | ​ | 9,293 | ​ | ​ | 5,629
Other items | ​ | ​ | 1,569 | ​ | ​ | (321)
Total income tax expense | ​ | ​ | 70,303 | ​ | ​ | 32,579
​ | ​ | ​ | ​ | ​ | ​ | ​
Total income tax represented by: | ​ | ​ | ​ | ​ | ​ | ​
Current income tax expense | ​ | ​ | 96,468 | ​ | ​ | 42,636
Deferred tax recovery | ​ | ​ | (26,165) | ​ | ​ | (10,057)
​ | ​ | ​ | 70,303 | ​ | ​ | 32,579
​
| (b) | Tax Amounts Recognized in Profit or Loss
​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | Years ended December 31,
​ | ​ | ​ | 2024 $ |  | ​ | 2023 $
Current tax expense | ​ | ​ | ​ | ​ | ​ | ​
Current taxes on profit for the year | ​ | ​ | 91,751 | ​ | ​ | 42,096
Changes in estimates related to prior years | ​ | ​ | 4,717 | ​ | ​ | 540
​ | ​ | ​ | 96,468 | ​ | ​ | 42,636
​ | ​ | ​ | ​ | ​ | ​ | ​
Deferred tax expense | ​ | ​ | ​ | ​ | ​ | ​
Origination and reversal of temporary differences and foreign exchange rate | ​ | ​ | (31,163) | ​ | ​ | (16,899)
Changes in estimates related to prior years | ​ | ​ | 5,003 | ​ | ​ | 6,879
Effect of differences in tax rates | ​ | ​ | (5) | ​ | ​ | (37)
Effect of changes in tax rates | ​ | ​ | - | ​ | ​ | -
​ | ​ | ​ | (26,165) | ​ | ​ | (10,057)
​ | ​ | ​ | ​ | ​ | ​ | ​
Total tax expense | ​ | ​ | 70,303 | ​ | ​ | 32,579
​
| (c) | Deferred Tax Balances
​ The significant components of the recognized deferred tax assets and liabilities are: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
As at December 31, |  | ​ | 2024 $ |  | ​ | 2023 $
Deferred tax assets: | ​ | ​ | ​ | ​ | ​ | ​
Reclamation and closure cost obligation | ​ | ​ | 12,377 | ​ | ​ | 15,011
Carried forward tax loss | ​ | ​ | 11,479 | ​ | ​ | 16,043
Accounts payable and accrued liabilities | ​ | ​ | 25,282 | ​ | ​ | 16,747
Deductibility of resource taxes | ​ | ​ | 182 | ​ | ​ | 154
Lease obligations | ​ | ​ | 7,664 | ​ | ​ | 7,972
Total deferred tax assets | ​ | ​ | 56,984 | ​ | ​ | 55,927
​ | ​ | ​ | ​ | ​ | ​ | ​
Deferred tax liabilities: | ​ | ​ | ​ | ​ | ​ | ​
Mineral properties | ​ | ​ | (159,319) | ​ | ​ | (193,646)
Mining and foreign withholding taxes | ​ | ​ | (243) | ​ | ​ | (1,124)
Equipment and buildings | ​ | ​ | (15,938) | ​ | ​ | (5,941)
Convertible debenture | ​ | ​ | (11,371) | ​ | ​ | (406)
Inflation | ​ | ​ | (196) | ​ | ​ | (598)
Inventory and other | ​ | ​ | (14,183) | ​ | ​ | (14,067)
Total deferred tax liabilities | ​ | ​ | (201,250) | ​ | ​ | (215,782)
​ | ​ | ​ | ​ | ​ | ​ | ​
Net deferred tax liabilities | ​ | ​ | (144,266) | ​ | ​ | (159,855)
​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​
Classification: | ​ | ​ | ​ | ​ | ​ | ​
Deferred tax assets | ​ | ​ | - | ​ | ​ | -
Deferred tax liabilities | ​ | ​ | (144,266) | ​ | ​ | (159,855)
Net deferred tax liabilities | ​ | ​ | (144,266) | ​ | ​ | (159,855)
​ The Company's movement of net deferred tax liabilities is described below: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | 2024 $ |  | ​ | 2023 $
At January 1 | ​ | ​ | 159,855 | ​ | ​ | 167,619
Deferred income tax recovery through income statement | ​ | ​ | (26,165) | ​ | ​ | (10,057)
Deferred income tax expense through equity | ​ | ​ | 10,576 | ​ | ​ | 2,293
At December 31 | ​ | ​ | 144,266 | ​ | ​ | 159,855
​
| (d) | Unrecognized Deferred Tax Assets and Liabilities
​ The Company recognizes tax benefits on losses or other deductible amounts where it is more likely than not that the deferred tax asset will be realized. The Company’s unrecognized deductible temporary differences and unused tax losses for which no deferred tax asset is recognized consist of the following amounts: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
As at December 31, |  | ​ | 2024 $ |  | ​ | 2023 $
Unrecognized deductible temporary differences and unused tax losses: | ​ | ​ | ​ | ​ | ​ | ​
Non-capital losses | ​ | ​ | 174,195 | ​ | ​ | 138,736
Provisions | ​ | ​ | 13,676 | ​ | ​ | 19,335
Mineral properties, plant and equipment | ​ | ​ | 238,795 | ​ | ​ | 163,508
Lease obligation | ​ | ​ | - | ​ | ​ | 1,729
Derivative liabilities | ​ | ​ | 25,808 | ​ | ​ | 23,395
Capital losses | ​ | ​ | 5,236 | ​ | ​ | -
Investments in equity securities and associates | ​ | ​ | 1,049 | ​ | ​ | 1,069
Unrecognized deductible temporary differences | ​ | ​ | 458,759 | ​ | ​ | 347,772
​ ​ ​ As at December 31, 2024, the Company has temporary differences associated with investments in subsidiaries for which an income tax liability has not been recognized as the Company can control the timing of the reversal of the temporary differences and the Company plans to reinvest in its foreign subsidiaries. The temporary difference associated with investments in subsidiaries aggregate as follows: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
As at December 31, |  | ​ | 2024 $ |  | ​ | 2023 $
Mexico | ​ | ​ | 14,942 | ​ | ​ | 27,491
Peru | ​ | ​ | 88,361 | ​ | ​ | 96,467
​
| (e) | Tax Loss Carry Forwards
​ Tax losses have the following expiry dates: ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
As at December 31, | ​ | ​ | Year of expiry | ​ | ​ | 2024 $ | ​ | ​ | Year of expiry |  | ​ | 2023 $
Canada | ​ | ​ | 2025 - 2044 | ​ | ​ | 200,452 | ​ | ​ | 2024 - 2043 | ​ | ​ | 210,847
Mexico | ​ | ​ | 2025 - 2034 | ​ | ​ | 22,997 | ​ | ​ | 2024 - 2033 | ​ | ​ | 6,623
​ In addition, as at December 31, 2024, the Company has accumulated Canadian resource related expenses of $7.5 million (December 31, 2023 - $8.2 million) for which the deferred tax benefit has not been recognized. ​
| (f) | International Tax Reform – Pillar Two Model Rules
​ On June 30, 2024, the Global Minimum Tax Act (GMTA) received royal assent thereby introducing the Pillar Two global minimum tax regime in Canada. The new GMTA is based on the OECD Pillar Two Global Anti-Base (GloBE) model rules (referred to as “Pillar Two”). The Pillar Two regime applies in Canada for fiscal years starting after December 31, 2023, for qualifying multinational groups. This includes the income inclusion rule and qualifying domestic minimum top-up tax. The legislation also includes a placeholder for the proposed undertaxed profits rule, intended to take effect for fiscal years beginning on or after December 31, 2024. ​ The GMTA introduces a 15% global minimum tax on the income of multinational enterprises with annual consolidated revenues of 750 million Euros or more in at least two of the four fiscal years immediately preceding the particular fiscal year and a business presence in at least one foreign jurisdiction. The GMTA has no impact on the Company’s current income taxes for the years ended December 31, 2024 and 2023. ​ From January 1, 2025, Pillar Two legislation will apply to the Company as the 2024 fiscal year was the second fiscal year of the four immediately preceding fiscal years in which the Company’s revenues exceed 750 million Euros. Of the jurisdictions the Company operates in, Pillar Two legislation has only been enacted in Canada, with an effective date of January 1, 2024. ​ The Company is currently in the process of assessing the potential impact of Pillar Two legislation, including the application of the transitional safe harbour rules.

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