Canadian Taxation Framework

Forms of Entity

Treatment of Expenditures in Canada

Flow-Through Shares

Investment Outside of Canada

Mergers & Acquisitions

Provincial Mining Taxes

Other Topics


Welcome to Mining Tax Canada

Canada has for decades enjoyed an important role in the world of mining and metallurgy. Blessed with an abundance of natural resources, Canada is a key supplier of minerals and metals to the world, and the home to many mining companies, both large and small. The mining of gold, nickel and a variety of other valuable minerals has played an important part in the evolution of Canada into a major developed economy, and Canada is among the world’s leading suppliers of uranium, nickel, aluminum, molybdenum and potash. The mining industry has always been a pillar of the Canadian economy, and the importance of this critical part of the fabric of the Canadian nation has never been more apparent than it is today.

Moreover, Canada is home to a strong community of professionals that plays an important role in mining projects around the world. On the operational side, Canada has an extraordinary body of world-class miners, geologists, metallurgists, and others involved in the discovery, extraction and processing of minerals, whose expertise is sought after in the mining industry both in Canada and abroad. The country is also home to a very strong financial sector that has unique expertise in the financing of mining, with corporations from around the world coming to Canada to raise money, find investors and list their shares on Canadian stock exchanges. The Toronto Stock Exchange (TSX) has well over 1,000 mining companies listed, plus hundreds more on its junior Venture Exchange (TSX-V), collectively more than any other exchange in the world: see here for more information. The Canadian legal community has also developed tremendous expertise in the mining area which is frequently used not only inside and outside Canada in structuring and managing mining ventures, but also to assist other countries in designing and establishing their legal regimes for mining.

Because so many mining companies have strong ties to Canada, understanding the Canadian tax system and how it affects mining projects is important. Taxes are often one of the biggest expenses in the mining business, so understanding how and when Canada taxes mining operations is essential. Investors are also keenly interested in how their investment in mining companies will be taxed, and obviously mining companies seeking to raise capital and attract investors need to be aware of how Canadian taxation laws may apply to them.

Mining Tax Canada is an educational resource for those interested in the Canadian taxation of mining. It seeks to explain the most important elements of the Canadian tax system as it applies to mining, in a non-technical, user-friendly way. The Canadian tax rules governing mining are very complex (even by tax standards) and require professional advice in order to navigate successfully. Each situation is unique, and it is important to obtain legal advice (which is confidential and protected from disclosure under Canadian law by solicitor-client privilege when obtained from a lawyer) in order to understand the risks and opportunities in any particular case. Keeping that in mind, we hope that Mining Tax Canada is a useful resource for you and a helpful step in understanding the Canadian taxation of mining. If you have any comments or suggestions, please feel free to contact us.