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Mining and Income Taxation (Tables)
12 Months Ended
Dec. 31, 2024
Major components of tax expense (income) [abstract]  
Summary of components of mining and income tax
United States Dollar
Figures in millions unless otherwise stated
2024
2023
2022
The components of mining and income tax are the following:
South African taxation
– company and capital gains taxation1
(4.1)
(6.0)
(65.3)
– dividend withholding tax
(13.1)
(5.9)
(13.1)
– prior year adjustment – current taxation
0.2
4.8
– deferred taxation
(63.0)
(84.6)
(80.2)
– prior year adjustment – deferred taxation
3.7
1.7
Foreign taxation
– current taxation
(514.6)
(443.0)
(386.1)
– dividend withholding tax
(6.3)
(5.4)
(4.7)
– prior year adjustment – current taxation2
(12.3)
(2.8)
(5.9)
– deferred taxation
(87.6)
77.8
111.5
Total mining and income taxation
(697.1)
(465.1)
(442.1)
Major items causing the Group's income taxation to differ from the maximum
South African statutory mining tax rate of 33.0% (2023: 33.0% and 2022: 34.0%) were:
Taxation on profit before taxation at maximum South African statutory mining tax rate
(655.9)
(399.4)
(395.7)
Rate adjustment to reflect the actual realised company tax rates in South Africa
and offshore3
56.5
41.4
65.9
Non-deductible share-based payments
(1.5)
(3.0)
(2.3)
Non-deductible exploration expense
(0.1)
(0.2)
(0.1)
Deferred tax assets not recognised on impairment of FSE
(38.6)
Non-deductible interest paid
(25.5)
(21.8)
(21.7)
Share of results of equity accounted investees, net of taxation
(17.7)
(10.8)
3.4
Non-taxable profit on disposal of asset held for sale - Asanko Gold
1.8
Non-taxable profit on disposal of assets held for sale - Rusoro
20.6
Non-taxable capital gains portion of Yamana break fee and transaction costs
5.8
18.2
Dividend withholding tax
(22.9)
(13.1)
(21.3)
Net non-deductible expenditure and non-taxable income
(28.6)
(17.6)
(18.2)
Deferred taxation movement on Peruvian Nuevo Sol devaluation against US dollar4
0.6
2.5
4.2
Various Peruvian non-deductible expenses
(11.0)
(6.1)
(5.3)
Deferred tax assets utilised/(not recognised) at Cerro Corona, net
15.3
(5.1)
(14.4)
Deferred tax assets utilised/(not recognised) at Damang and Tarkwa
3.9
(30.3)
1.2
Deferred tax assets not recognised at Windfall5
(17.2)
Deferred tax recognised at Salares Norte
(4.2)
Prior year adjustments
(8.0)
(3.3)
(2.7)
Deferred tax charge on change of tax rate at South Deep
0.9
(5.7)
Other
(8.4)
(4.1)
(4.7)
Total mining and income taxation
(697.1)
(465.1)
(442.1)
1The US$65.3 million in 2022 includes capital gains taxation of US$65.2 million paid to South African Revenue Services on Yamana break fee.
2The US$12.3 million in 2024 relates mainly to additional transfer pricing charges at Tarkwa. The US$5.9 million in 2022 comprised US$19.2 million additional transfer
pricing charges at Tarkwa and Damang, partially offset by a refund of US$13.3 million relating to hedges in Peru.
3Due to different tax rates in various jurisdictions, primarily South Africa, Ghana, Australia and Peru.
4The functional currency of Cerro Corona is US Dollar, however, the Peruvian tax base is based on values in Peruvian Nuevo Sol.
5Deferred tax assets at Windfall of US$17.2 million were not recognised during the year ended 31 December 2024 to the extent that there is insufficient future taxable
income available. The Windfall Project is still in the feasibility phase and a final investment decision is expected to the made in 2026.
Summary of domestic and foreign current tax rates
United States Dollar
2024
2023
2022
South Africa – current tax rates
Mining tax1
Y = 33 – 165/X
Y = 33 – 165/X
Y = 34 – 170/X
Non-mining tax2
27.0%
27.0%
28.0%
Company tax rate
27.0%
27.0%
28.0%
International operations – current tax rates
Australia
30.0%
30.0%
30.0%
Ghana
32.5%
32.5%
32.5%
Peru
29.5%
29.5%
29.5%
1South 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. During June 2022, the South African Revenue Services published the draft 2022 Rates & Monetary
Bill, inclusive of an amendment to the gold tax formula from Y = 34 – 170/X to Y = 33 – 165/X in respect of year assessments ending on or after 31 March 2023 and this
amendment was effective for the year ended 31 December 2023. This resulted in the effective mining tax rate used for deferred tax purposes for Gold Fields Operations
Limited ("GFO") and GFI Joint Venture Holdings (Proprietary) Limited ("GFIJVH"), owners of the South Deep mine, decreasing from 29% at 31 December 2021 to 28% at
31 December 2022, amounting to a charge of R76.2 million (US$4.6 million) through profit or loss in 2022 (2024: 29.00%, 2023: 28% and 2022: 29%). In the formula
above, Y is the percentage rate of tax payable and X is the ratio of mining profit, after the deduction of redeemable capital expenditure, to mining revenue expressed as
a percentage.
2Non-mining income of South African mining operations consists primarily of interest income. The corporate income tax rate was reduced from 28% to 27% for tax years
ended on or after 31 March 2023 and was effective for the year ended 31 December 2023.
Summary of estimated amount available for setoff against future domestic and foreign income pre-tax At 31 December 2024, the Group had the following estimated amounts available for set-off against future income:
South African Rand
2024
2023
Gross
unredeemed
capital
expenditure
Gross tax
losses
Gross tax
losses not
recognised
Gross
unredeemed
capital
expenditure
Gross tax
losses
Gross tax
losses not
recognised
R’million
R’million
R’million
R’million
R’million
R’million
South Africa1
Gold Fields Operations Limited
6,230.7
626.8
7,688.5
619.6
GFI Joint Venture Holdings (Pty) Limited
8,980.1
578.1
10,253.9
616.9
Gold Fields Holdings Company Limited
54.0
54.0
53.2
53.2
15,210.8
1,258.9
54.0
17,942.4
1,289.7
53.2
1These deductions are available to be utilised against income generated by the relevant tax entity and do not expire unless the tax entity concerned ceases to operate
for a period of longer than one year. Under South African mining tax ring-fencing legislation, each tax entity is treated separately and as such these deductions can only
be utilised by the tax entities in which the deductions have been generated. South African tax losses and unredeemed capital expenditure have no expiration date.
United States Dollar
2024
2023
Gross
unredeemed
capital
expenditure
Gross tax
losses
Gross tax
losses not
recognised
Gross
unredeemed
capital
expenditure
Gross tax
losses
Gross tax
losses not
recognised
US$ million
US$ million
US$ million
US$ million
US$ million
US$ million
South Africa1
Gold Fields Operations Limited
330.7
33.3
420.1
33.9
GFI Joint Venture Holdings (Pty) Limited
476.7
30.7
560.3
33.7
Gold Fields Holdings Company Limited
2.9
2.9
2.9
2.9
807.4
66.8
2.9
980.5
70.5
2.9
International operations
Exploration entities2
186.6
186.6
224.4
224.4
Minera Gold Fields Salares Norte3
507.3
366.7
568.7
130.8
Windfall Mining Group Inc.4,5
390.5
390.5
25.9
25.9
Abosso Goldfields Limited6,7
27.6
27.6
28.1
28.1
Gold Fields Ghana Limited6,8
26.7
26.7
30.4
30.4
507.3
998.1
631.4
568.7
439.6
308.8
1These 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.
2The total tax losses of US$186.6 million (2023: US$224.4 million) comprise US$1.1 million (2023: US$2.2 million) tax losses that expire between
one and two years, US$0.9 million (2023: US$4.0 million) tax losses that expire between two and five years, US$nil (2023: US$1.1 million) tax
losses that expire between five and 10 years, US$158.0 million (2023: US$168.2 million) tax losses that expire after 10 years and US$26.6 million
(2023: US$48.9 million) tax losses that have no expiry date.
3These deductions are available to be utilised against income generated by the relevant tax entity and do not expire.
4The increase in tax losses arose from pre-existing losses acquired as part of the Osisko asset acquisition on 25 October 2024 and additional
project spending post-closing. The Windfall Project is still in the feasibility phase and a final investment decision is expected to be made in 2026,
therefore the deferred tax asset relating to the tax losses were not recognised at 31 December 2024. The total tax losses of US$390.5 million
(2023: US$25.9 million) comprise US$5.0 million (2023: US$nil) tax losses that expire between two and five years, US$29.4 million (2023: US$nil)
tax losses that expire between five and 10 years, US$284.2 million (2023: US$25.9 million) tax losses that expire after 10 years and US$71.9
million (2023 US$nil) tax losses that have no expiry date. Tax losses of US$25.9 million at 31 December 2023 were previously included in
exploration entities.
5Unredeemed capital expenditure of $212.2 million relates to the assets acquired as part of the Osisko asset acquisition on 25 October 2024 and
additional capital expenditure post-closing. The Windfall Project is still in the feasibility phase and a final investment decision is expected to be
made in 2026, therefore the deferred tax asset relating to the unredeemed capital expenditure was not recognised at 31 December 2024. These
deductions are available to be utilised against income generated by the relevant tax entity and do not expire.
6Tax losses may be carried forward for five years. These losses expire on a first-in-first-out basis. Tax losses of US$32.6 million (2023: US$48.1
million) between one and two years and tax losses of US$21.7 million (2023: US$10.4 million) expire between two and five years.
7At 31 December 2024, tax losses at Damang of US$27.6 million (2023: US$28.1 million) comprise deferred tax assets not recognised relating to
financial instruments losses.
8At 31 December 2024, deferred tax assets at Tarkwa of US$26.7 million (2023: US$30.4 million) not recognised relating to losses on financial
instruments.