Tanya Jakusconek

Brian MacArthur

Daniel Major

Bernie Picchi

Bernie Pichy

Cosmos Chiu

Fahad Tariq

Heiko Ihle

John Tumazos

Larry Liu

Lyle Green

Matthew Murphy

Diego Termite

Joshua Wolfson

Lawson Winder

Martin Pradier

- Franco-Nevada Corporation has reached a settlement with the Canada Revenue Agency (CRA) regarding tax disputes related to reassessments under transfer pricing rules for the **2013 to 2019 taxation years**.  **[1456346_0001558370-25-012025_fnv-20250911xex99d1.htm:0]** 
- The settlement dictates that Franco-Nevada will **not be required to pay any tax in Canada** on the foreign earnings of its wholly-owned foreign subsidiaries, Franco-Nevada (Barbados) Corporation and Franco-Nevada Mexico Corporation, S.A. de C.V., for the disputed period.  **[1456346_0001558370-25-012025_fnv-20250911xex99d1.htm:0]** 
- The service fee mark-up applied to Franco-Nevada's cost of providing services to these subsidiaries will be adjusted to **30%** (up from a current range of 7-20%), resulting in Franco-Nevada being subject to Canadian tax on additional income of **C$1.4 million** for the 2013 to 2019 taxation years.  **[1456346_0001558370-25-012025_fnv-20250911xex99d1.htm:0]**  However, **no additional cash taxes are anticipated** for these years due to the application of non-capital losses.  **[1456346_0001558370-25-012025_fnv-20250911xex99d1.htm:0]** 
- Transfer pricing penalties reflected in the reassessments will be **reversed**, and interest charges will be reduced.  **[1456346_0001558370-25-012025_fnv-20250911xex99d1.htm:0]**

Franco-Nevada settles Canadian tax disputes

- Franco-Nevada Corporation has reached a settlement with the Canada Revenue Agency (CRA) regarding tax reassessments for the **2013 to 2019 taxation years** related to income generated by its foreign subsidiaries, Franco-Nevada Barbados and Franco-Nevada Mexico.  **[1456346_20250911TO71929:0]** 
- The settlement dictates that Franco-Nevada will **not be required to pay any tax in Canada on the foreign earnings** of these subsidiaries for the 2013 to 2019 taxation years.  **[1456346_20250911TO71929:0]** 
- The service fee mark-up applied to Franco-Nevada's cost of providing services to its foreign subsidiaries will be **adjusted from the current range of 7-20% to 30%**.  **[1456346_20250911TO71929:0]** 
- This adjustment will result in Franco-Nevada being subjected to Canadian tax on an additional **C$1.4 million** in income for the 2013 to 2019 taxation years, but the company **does not anticipate any additional cash taxes** will arise due to the application of non-capital losses.  **[1456346_20250911TO71929:0]** 
- Transfer pricing penalties reflected in the reassessments will be reversed, and interest charges will be reduced.  **[1456346_20250911TO71929:0]**  The company believes the transfer pricing principles established by this settlement will apply to years after 2019, provided there are no material changes.  **[1456346_20250911TO71929:0]**

Franco-Nevada Reaches Settlement on Canadian Tax Disputes

FRANCO NEVADA (FNV)