About This Book

We have written this book for business entities that invest 
in mining activities to help them understand the Canadian 
tax regime and how it applies to such activities in Canada 
and abroad. The book is a summary of the relevant Canadian 
legislation and provides an overview of the broad principles 
applicable to any particular mining activity. The statements of 
the law are current to June 30, 2013. At that time, there was 
legislation in draft or proposal form that had not been finalized. 
For ease of discussion, we have assumed that all the relevant 
legislation will become law. Where proposed legislation is not 
enacted, the relevant government usually provides transitional 
legislation for the benefit of those taxpayers that relied on 
the proposed legislation. In a few instances, where there are 
proposals which have not been reduced to legislation, we have 
described the nature of the proposals.

This book concentrates on the federal, provincial, and territorial 
taxes applicable to mining activities and does not consider 
other taxes and charges, such as payroll taxes, to which 
all taxpayers carrying on business may be liable. A person 
contemplating carrying on business in Canada should consult 
a tax adviser about the application of these other taxes.

The relevant tax rules are detailed and complex, and we 
have not endeavoured to discuss the many nuances of such 

legislation. We have eschewed the word “generally” and 
the phrase “in general” in order to make the text simpler 
and more readable. We accept that there may be esoteric 
exceptions to many of our statements, but we consider it 
more important to give readers straightforward statements 
that may not be true in every factual circumstance than to 
bog down the reader by forcing her or him to read unending 
caveats. Therefore, this book should not be seen as a 
substitute for consultation with a knowledgeable tax adviser. 
For a more detailed and technical review of the federal 
legislation, see Canadian Resource Taxation, General Editors, 
Brian R. Carr and C. Anne Calverley, QC (Toronto: Carswell, 
looseleaf).

We have attempted to make the content of the book user-
friendly by keeping specific references to legislative provisions 
to a bare minimum. In addition, we have provided a glossary 
at the end of the book that includes concise definitions of tax 
and mining industry terms. Throughout the text, the tax terms 
and abbreviations are highlighted in bold type the first time 
they are used in a section, to refer the reader to the glossary. 
We have provided cross-references where a particular concept 
is more fully discussed in another section of the book; these 
cross-references are colour-coded and underlined for easy 
identification. Finally, an index is included to guide the reader 
to the pages where specific topics are discussed.

© 2013 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms 
affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

 Introduction 

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