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United States Dollar |
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Figures in millions unless otherwise stated |
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2017 |
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2016 |
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9. |
MINING AND INCOME TAXATION |
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The components of mining and income tax are the following: |
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South African taxation |
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– non-mining tax |
– |
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(1.2) |
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(1.0) |
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– Company and capital gains taxation |
(1.1) |
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(1.1) |
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(3.9) |
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– prior year adjustment – current taxation |
0.7 |
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0.2 |
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0.3 |
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– deferred taxation |
208.5 |
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12.1 |
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(9.5) |
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Foreign taxation |
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– current taxation |
(127.9) |
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(199.8) |
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(193.3) |
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– dividend withholding tax |
(13.7) |
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– |
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– |
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– prior year adjustment – current taxation |
(3.7) |
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(2.8) |
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(6.3) |
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– deferred taxation |
3.1 |
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19.4 |
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24.2 |
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Total mining and income taxation |
65.9 |
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(173.2) |
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(189.5) |
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Major items causing the Group’s income taxation to differ from the maximum South African statutory mining tax rate of 34.0% (2017: 34.0% and 2016: 34.0%) were: |
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Taxation on profit before taxation at maximum South African statutory mining tax rate |
139.6 |
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(51.8) |
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(121.5) |
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Rate adjustment to reflect the actual realised company tax rates in South Africa and offshore |
(6.7) |
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19.2 |
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22.4 |
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Non-deductible share-based payments |
(12.8) |
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(9.1) |
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(4.8) |
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Non-deductible exploration expense |
(22.1) |
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(19.7) |
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(15.2) |
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Deferred tax assets not recognised on impairment and reversal of impairment of investments1 |
(12.5) |
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13.3 |
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– |
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Impairment of South Deep goodwill |
(24.4) |
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(94.5) |
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– |
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Non-deductible interest paid |
(25.5) |
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(24.2) |
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(24.2) |
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Non-taxable profit on disposal of investments |
– |
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– |
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0.8 |
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Non-taxable profit on buy-back of notes |
– |
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– |
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6.0 |
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Share of results of equity-accounted investees, net of taxation |
(4.5) |
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(0.4) |
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(0.8) |
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Non-taxable gain on acquisition of Asanko |
17.6 |
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– |
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– |
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Non-taxable fair value gain on Maverix warrants |
1.3 |
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– |
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– |
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Non-taxable profit on dilution of Gold Fields’ interest in Maverix |
1.4 |
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– |
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– |
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Dividend withholding tax |
(15.5) |
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– |
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– |
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Net non-deductible expenditure and non-taxable income |
(7.6) |
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(5.3) |
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(9.7) |
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Deferred tax raised on unremitted earnings at Tarkwa and Cerro Corona (2017: Tarkwa) |
(1.1) |
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(9.5) |
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– |
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Deferred taxation movement on Peruvian Nuevo Sol devaluation against US Dollar2 |
(1.2) |
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5.2 |
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(1.1) |
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Various Peruvian non-deductible expenses |
(7.5) |
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(5.3) |
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(8.3) |
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Deferred tax assets not recognised at Cerro Corona (2017: Cerro Corona and Damang)3 |
(14.9) |
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(12.9) |
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(34.9) |
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Utilisation of tax losses not previously recognised at Damang |
– |
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7.1 |
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– |
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Deferred tax assets recognised at Damang (2017: Cerro Corona and Damang)4 |
6.5 |
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19.8 |
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– |
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Additional capital allowances recognised at South Deep5 |
69.8 |
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– |
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– |
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Deferred tax charge on change of tax rate at South Deep (2016: Peruvian and Ghanaian operations) |
(10.9) |
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– |
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8.6 |
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Prior year adjustments |
(3.0) |
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(2.6) |
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(6.0) |
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Other |
(0.1) |
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(2.5) |
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(0.8) |
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Total mining and income taxation |
65.9 |
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(173.2) |
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(189.5) |
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1 |
Deferred tax assets not recognised on impairment of investments relate to the impairment of FSE (2017: reversal of impairment of APP). Refer to note 6 for details of
impairments. |
2 |
The functional currency of Cerro Corona is US Dollar, however, the Peruvian tax base is based on values in Peruvian Nuevo Sol. |
3 |
Deferred tax assets amounting to US$14.9 million (2017: US$12.9 million and 2016: US$34.9 million) were not recognised during the year at Cerro Corona and Damang
to the extent that there is insufficient future taxable income available. At Cerro Corona, deferred tax assets amounting to US$14.9 million (2017: US$12.9 million and
2016: US$33.5 million) were not recognised during the year related to deductible temporary differences on additions to fixed assets in the current financial year that
would only reverse after the end of the life-of-mine (“LoM”) of Cerro Corona. At Damang, deferred tax assets amounting to US$nil (2017: US$nil and 2016: US$1.4 million)
were not recognised during the year related to net deductible temporary differences reversing in the current financial year. In making this determination, the Group
analysed, among others, forecasts of future earnings and the nature and timing of future deductions and benefits represented by deferred tax assets. |
4 |
Due to year-end assessments, deferred tax assets amounting to US$nil (2017: US$17.3 million) and US$6.5 million (2017: US$2.5 million) were recognised at Cerro
Corona and Damang, respectively, to the extent that there is sufficient future taxable income available. During 2017, Cerro Corona completed a pre-feasibility study
extending the LoM from 2023 to 2030. A significant portion of the deductible temporary differences on fixed assets that were scheduled to reverse after the end of the
LoM at Cerro Corona will now reverse over the extended LoM, resulting in the recognition of deferred tax assets amounting to US$17.3 million in 2017. At Damang, the
LoM indicated that the mine would make taxable profits in the future that would support the write back of a portion of the deferred tax asset amounting to US$6.5 million
(2017: US$2.5 million) in 2018. In making this determination, the Group analysed, among others, forecasts of future earnings and the nature and timing of future
deductions and benefits represented by deferred tax assets. |
5 |
During 2014, the South African Revenue Service (“SARS”) issued a Finalisation of Audit Letter (“the Audit Letter”) stating that SARS had disallowed US$182.2 million of
GFIJVH’s gross recognised capital allowance of US$925.5 million. On 30 May 2018, GFIJVH and SARS entered into a confidential settlement agreement (as provided
for in the Tax Administration Act) in full and final settlement of this matter. As a result of the settlement GFIJVH recognised an additional US$185.1 million of capital
allowances with a tax effect on this amount of US$53.7 million. Refer note 35 on Contingent Liabilities for further details. |
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1 |
South African mining tax on mining income is determined according to a formula which takes into account the profit and revenue from mining
operations. South African mining taxable income is determined after the deduction of all mining capital expenditure, with the proviso that this
cannot result in an assessed loss. Capital expenditure amounts not deducted are carried forward as unredeemed capital expenditure to be
deducted from future mining income. Accounting depreciation is ignored for the purpose of calculating South African mining taxation. The
effective mining tax rate for Gold Fields Operations Limited (“GFO”) and GFI Joint Venture Holdings Proprietary Limited (“GFIJVH”), owners
of the South Deep mine, has been calculated at 29% (2017: 30% and 2016: 30%).
In the formula above, Y is the percentage rate of tax payable and X is the ratio of mining profit, after the deduction of redeemable capital
expenditure, to mining revenue expressed as a percentage. |
2 |
Non-mining income of South African mining operations consists primarily of interest income. |
3 |
On 11 March 2016, Gold Fields signed a development agreement with the Government of Ghana for both the Tarkwa and Damang mines.
This agreement resulted in a reduction in the corporate tax rate from 35.0% to 32.5%, effective 17 March 2016. |
Deferred tax is provided at the expected future rate for mining operations arising from temporary differences between
the carrying values and tax values of assets and liabilities.
At 31 December 2018, the Group had the following estimated amounts available for set-off against future income
(pre-tax):
|
United States Dollar |
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2017 |
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Figures in millions unless otherwise stated |
Gross
unredeemed
capital
expenditure |
Gross tax
losses |
Gross
deferred tax
asset not
recognised |
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South Africa1 |
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GFO |
638.0 |
206.4 |
– |
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716.4 |
192.5 |
– |
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GFIJVH2, 3 |
1,003.1 |
41.0 |
– |
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2,427.1 |
– |
1,501.6 |
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Gold Fields Group Services Proprietary Limited |
– |
1.3 |
– |
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– |
– |
– |
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1,641.1 |
248.7 |
– |
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3,143.5 |
192.5 |
1,501.6 |
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International operations |
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Exploration entities4 |
– |
430.0 |
430.0 |
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– |
445.9 |
445.9 |
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Abosso Goldfields Limited5 |
– |
80.9 |
– |
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– |
201.4 |
63.5 |
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– |
510.9 |
430.0 |
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– |
647.3 |
509.4 |
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1 |
These deductions are available to be utilised against income generated by the relevant tax entity and do not expire unless the tax entity
concerned ceases to operate for a period of longer than one year. Under South African mining tax ring-fencing legislation, each tax entity is
treated separately and as such these deductions can only be utilised by the tax entities in which the deductions have been generated. South
African tax losses and unredeemed capital expenditure have no expiration date. |
2 |
The above US$1,003.1 million (2017: US$2,427.1 million) comprises US$1,003.1 million (2017: US$925.5 million) gross recognised capital
allowance and US$nil (2017: US$1,501.6 million) gross unrecognised capital allowance. |
3 |
During 2014, the South African Revenue Service (“SARS”) issued a Finalisation of Audit Letter (“the Audit Letter”) stating that SARS
had disallowed US$182.2 million of GFIJVH’s gross recognised capital allowance of US$925.5 million. On 30 May 2018, GFIJVH and
SARS entered into a confidential settlement agreement (as provided for in the Tax Administration Act) in full and final settlement of this matter.
As a result of the settlement GFIJVH recognised an additional US$185.1 million of capital allowances, previously not recognised, with a tax
effect on this amount of US$53.7 million. Refer note 35 on contingent liabilities for further details. |
4 |
The total tax losses of US$430.0 million (2017: US$445.9 million) comprise US$18.6 million (2017: US$22.9 million) tax losses that expire
between one and two years, US$27.6 million (2017: US$57.6 million) tax losses that expire between two and five years, US$20.3 million
(2017: US$30.4 million) tax losses that expire between five and 10 years, US$42.3 million (2017: US$43.2 million) tax losses that expire after
10 years and US$320.9 million (2017: US$291.8 million) tax losses that have no expiry date. |
5 |
Tax losses may be carried forward for five years. These losses expire on a first-in-first-out basis. Tax losses of US$19.0 million (2017:
US$44.5 million) expire in two years, tax losses of US$2.9 million (2017: US$19.0 million) expire in three years, tax losses of US$31.5 million
(2017: US$91.7 million) expire in four years and tax losses of US$27.5 million (2017: US$46.2 million) expire in five years. |
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