Pueblo Viejo , Sánchez Ramírez, Dominican Republic Overview Principal Producing Development Highlighted Evaluation Evaluation/Exploration Mineral Resources and Reserves 5 Depletion, Depreciation and Amortization of Stream and Royalty Interests Stream and royalty interests include acquired stream and royalty interests in producing, development, evaluation and exploration stage properties. The costs of acquired stream and royalty interests are capitalized as tangible assets as such interests do not meet the definition of a financial asset. Producing stage stream and royalty interests are depleted using the units of production method over the life of the mineral property (as stream sales occur or royalty payments are recognized), which is estimated using proven and probable mineral reserves as provided by the operator. Development stage mineral properties, which are not yet in production, are not depleted until the property begins production. Evaluation and exploration stage mineral properties, where there are no proven and probable mineral reserves, are not depleted. Tax Treatment of Streams and Royalties The following is a high-level discussion on tax applicable to our two segments, streams and royalties. Our stream contracts are owned and managed by our Swiss subsidiary. Our streaming business is engaged in metal purchase and sales, which generates active income subject to Swiss and U.S. Global Intangible Low-Taxed Income (“GILTI”) tax. Switzerland has a treaty network with the U.S. and other countries and has a competitive corporate tax environment. Income from our streaming business is subject to the GILTI regime, which effectively imposes a worldwide minimum tax on the foreign earnings of U.S. companies. Our streaming business has an approximate tax rate of 13.1% to the end of 2025 and 16.4% thereafter, which includes Swiss statutory rates and the U.S. corporate tax per the GILTI regime. Royalties are owned and managed by our U.S. and Canadian companies. Royalties are non-operating interests and, as such, generate passive income. Income from royalties is generally taxed at the higher of foreign or U.S. tax rates. When allowable, foreign tax credits are claimed to minimize double taxation. Our royalty business is subject to a minimum U.S. and state tax rate of 22%, with higher rates payable in certain foreign jurisdictions.
2023 Asset Handbook Page 6 Page 8