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Mining sector Nordic Investment in Mexico Mining
Mining Nordic Investment in Mexico Mining sector The purpose of this document is to be only a general reference on certain areas of interest. The application and effect of the law may vary depending on the specific data included herein. Omissions or inaccuracies are possible due to the changing nature of the laws, rules and regulations. This document is distributed based on the understanding that the authors and editors are not bound to offer legal, accounting and tax advice, nor other professional services. Therefore, this document cannot replace direct accounting, tax or legal professional advice, or any other type of advice. Before making any decision or taking any action, we recommend calling upon a professional of PwC Mexico. Even though we made our best effort to base the contents of this document on reliable sources, PwC Mexico is not responsible for any mistake or omission resulting from the use of this information. The data included in this document is provided “as found” in the original source, without guaranteeing its integrity, precision, accuracy or assuming the responsibility for the results obtained through its application; and without any other kind of guarantee, expressed or implicit, including but not limited to performance, commercialisation and convenience guarantees to reach an specific goal. PwC Mexico, its affiliated companies/firms, partners, agents or employees cannot be held accountable for any decision or measure implemented by you or any other person based on this information, as well as for any resulting damage or harm, specific or similar, including a notification about the possibility of such damage. Overview Mexico is a top destination for exploration investment in Latin America. According to the Mexican Mining Chamber (CAMIMEX), in 2012 mining investment grew by 43% compared to the previous year. There are over 800 active exploration projects mainly in gold, silver, copper, zinc and lead. More than 15 projects are expected to go into production within the next couple of years, and 35 projects are in advanced exploration. With 70% of its territory still unexplored, Mexico still has a lot to offer to the mining industry. Currently however, primarily as a result of recent tax reforms, the mining community has expressed dissatisfaction over the sector’s prospects. Mining companies are working to quantify how the recently approved 7.5% royalty on mining profits and 0.5% environmental fee on revenues from precious metals will affect their operations as of 2014. Companies are realigning projects, budgets and their organisational structures to determine how to best ensure returns for their shareholders in this new environment. What will the future be for Mexico’s mining industry? Will it lose its competitiveness? Will investment capital flow to other lower cost jurisdictions in the region or the world? Mineral prices and demand is low at the moment. The future is challenging. Different perspectives Mexico’s tax reform is one of the key initiatives under the Pact for Mexico framework brought forth by the federal government, aimed at attracting more foreign direct investment in industries like communications, energy, technology, financial services and mining. The ultimate goal is to make Mexico more competitive on a global basis by leveraging the benefits of the increased economic activity to invest in security, education, healthcare, infrastructure and other pressing issues that limit Mexico’s development. The tax bill was initially presented in March 2013 by a Deputy representing the Institutional Revolutionary Party (PRI). The proposal was partly incorporated into the final bill initiative presented by the Federal Government in September 2013. When the tax reform was initially created, commodity prices were high and mining companies were enjoying very profitable operations. The mood within the global mining industry was to grow at any cost. Today the industry faces a very different environment. Demand from countries like China has not increased at the same high rate as in the last decade, the economies in other parts of the world have slowed and as a result, the demand for metals has dropped. There is a depressed mining industry landscape with lower commodity prices, higher operating costs, and limited capital, which explains the concern of miners with the implementation of higher tax regulations. Other amendments In addition to the 7.5% royalty on profits and 0.5% tax on precious metals, other mining-specific reforms were introduced: •Tax deduction of exploration expenses will be made in a ten-year period straight-line basis instead of the total investment in the year incurred. Development expenses are not included, meaning they could be totally tax deducted the year they are incurred. •The option for the lump-sum deduction of assets (immediate depreciation) has been eliminated. Instead, depreciation and amortization will be applicable on a straight-line basis. •A 50% tax on idle properties that do not operate for two consecutive years within the first ten years of obtaining the mining concession—or 100% if this occurs after the eleventh year of obtaining the concession—will be imposed. Changes were also made to income tax rules on withholding tax on corporate dividends, the tax consolidation regime, provisions for foreign residents, among others. If the tax amendments do result in a loss of competitiveness, bigger efforts will be needed for Mexico to continue attracting and increasing investment in the sector from both domestic and foreign companies to remain an important mining destination. With regard to the future, the reality is that Mexico has immense mineral potential and will continue to be of interest to miners. However, mining companies will need to be more strategic in their options to make their business more profitable. For example, they will need to continue incorporating programmes to increase productivity, use green energy, improve their human capital utilisation and effectively manage stakeholder relations, including relations with the communities. The industry will be inwardly focused for a couple of years while companies adjust to the new operating environment. Mining investment forecasts will certainly need to be re-estimated, and some companies, mostly juniors and mid-size, may decide to divert their investments to other territories. The industry will increase its focus on managing costs better and improving productivity in a sustainable manner. Making their mine competitive when prices are low always positions companies better when prices increase— which they will. Mexico’s status as a top mining destination in the region will very likely be challenged, but it will definitely continue to be a good place for mining in the long term1. Source: José Almodovar, PwC México Mining leader, Pacific Alliance leaders “Improving business models” 1 PwC Mexico 1 World economy is a key driver for the mining industry Five years after the global financial crisis, the world economy continues to struggle. Growth in developing countries, the main contributors to global growth, accelerated in the third quarter of 2012, although output of Latin America and the Caribbean has slowed, as compared to the pre-crisis period. Global growth is expected to strengthen to 3.1 and 3.3 percent in 2014 and 20152. The share of mining activities of total industry value ranged from a low of just over 0.04% in Mauritius, 0.06% in Puerto Rico, and 0.07% in Liberia to over 87.54% in Equatorial Guinea, and 69.6% in Libya in 20093. The share of the mining industry in total value added increased by nearly 43.7% from 2000 to 2009. In 2009, three countries (Liberia, Jordan, and Montserrat) increased their mining share by 150%, 96.46%, and 90.07%, respectively, over the previous year. The Dominican Republic, Singapore, and Tunisia, on the other hand, decreased their share by 50.68%, 33.33%, and 30.43%, respectively, for the 2008-2009 period. The global mining sector went into steep decline during the financial crisis, although it remained one of the main pillars of the global economy acting as a supplier for a wide range of industries. Rank and share in production of mineral commodities (precious metals; gold and silver) as a % of global total volume by country, 2012 World mining production as a % share by country, 2009 USA 46.6% Rest of Americas 20.2% Brazil 13.8% Canada 11.5% Mexico 7.9% Source: ISI Emerging Market. Silver production per country 2012 Nr 1 Mexico,17.7% Nr 2 China, 15.8% Nr 3 Peru,14.4% Nr 4 Australia, 7.9% Nr 5 Russia, 6.2% Nr 6 Bolivia, 5.4% Nr 7 Poland, 4.9% Nr 8 Chile, 4.7% Nr 9 USA,4.4% Nr 10 Canada,2.2% Source: USGS. 2 2 Nordic investment in Mexico 3 Source: World Bank and the United Nations. Source: United Nations Statistics. Gold production per country 2012 Nr 1 China,13.7% Nr 2 Australia, 9.3% Nr3 USA, 8.5% Nr4 Russia,7.6% Nr5 South Africa, 6.3% Nr 6 Peru, 6.1% Nr 7 Canada, 3.8% Nr 8 Indonesia, 3.5% Nr 9 Uzbekistan, 3.3% Nr 9 Ghana, 3.3% PwC Mexico 3 Industry establishments and institutions The mining industry in Mexico is regulated by the Department of the Economy through the General Mining Coordination and General Mining Department, which is divided into different offices, sub-offices, and mining agencies. Government Authorities Ministry of Economy Secretaría de Economía (SE) General Direction for Mining Promotion Established for: Established for maintenance of relations with the State Governments and Social Mining. • Public mining registry; • Maintenance of Mining Cartography Registry (Cartografía Minera); • Identification of all mineral deposits in the country and supply of geological information to the public; • Promotion of exploration, exploitation, benefaction, industrialisation, and commercialisation of minerals by providing technical assistance and credit to mining concession holders. www.economia.gob.mx General Mining Coordination (Coordinadora General de Minería de la Secretaría de Economía) Established to coordinate Mining Policy, implementation, and enforcement of the Mining Law (Ley Minera). General Direction for Mines Responsible for application of the Mining Law. Mexican Geologic Service (Servicio Geologico Mexicano) Established to generate and provide knowledge for territory planning and better exploitation of natural resources. Mining Promotion Trust Financing of small and medium companies interested in investing in the mining industry. Influential organisations and industry associations 4 Industry establishments and institutions Description Website ProMéxico Established to promote the export supply and support the internationalisation of Mexican companies by attracting foreign direct investment. www.promexico.gob.mx La Cámara Minera de México (CAMIMEX) Established to elaborate laws, standards and regulations related to the sector, promote mining activities, and financially support universities that offer related degrees. www.camimex.org.mx Nordic investment in Mexico Modern trends in the Mexican mining industry Variation of Mexican mining production of precious metals as an annual % change, 2007-12 30% Gold While the drop in prices for some metals has not been as severe as during the 2008-09 global recession, the fall from record or near-record levels in 2011 has created some setbacks. A drop in commodity prices has led to lower revenues for mining companies, causing most to cut back on operations and spending. In some extreme cases, companies have taken billions of US dollars worth of write downs to account for the lower value of their assets compared to only a couple of previous years. Few commodities in the mining sector have escaped the downturn caused by global economic uncertainty and volatile markets. Gold, silver and copper are among the most closely watched metals. They were also some of the hardest hit in 2013. 25% We believe that the long-term fundamentals supporting metal prices remain strong and will help to drive the industry’s turnaround story. While gold, silver and copper may not reach record levels in the near future, we expect prices to increase, alongside a stabilising global economy4. Source: Statistical Yearbook of the Mexican Mining, 2013, 2012, 2011, 2010, 2009, 2007, 2008 Silver 20% 15% 10% 5% 0% -5% 2007 2008 2009 2010 2011 2012 Gold production by state, 2012 29.2% Mexican mining, digging its way in the world 21.1% Thanks to large reserves of important minerals and due to investment friendly business environment, Mexico is one of the major players of the global mining industry. 19.2% 10.9% Mexico has a long history in mining that dates back to the colonial period, diverse geography and rich geology, and a skilled workforce to foster a strong, sustainable and dynamic mining industry. Mexico is an important global player for mining investment and production5. 10.4% Sonora Zacatecas Chihuahua Guerrero Others Durango 9.2% Source: SE, January 2014 Silver production by state, 2012 43.6% 19.2% Zacatecas Chihuahua Others 15% Durango 12.1% Sonora 6.7% México 3.4% Source: SE, January 2014 4 5 Source: PwC “Gold, silver and copper price report 2014”. Source: ProMexico (thhp://negocios.promexico.gob.mx/20.2.2014) PwC Mexico 5 Variation of Mexican mining production of industrial non-metallic minerals as an annual % change, 2007-12 200% Copper production by state, 2012 Sonora Copper Zacatecas Zinc 150% San Luis Potosí Molybdenum 77.8% Lead 100% Others Chihuahua 10.2% 4.6% 4.2% 3.2% 50% Source: SE, January 2014 Lead production by state, 2012 0% 2007 2008 2009 2010 2011 2012 Zacatecas Chihuahua -50% 53.2% Source: Statistical Yearbook of the Mexican Mining, 2013, 2012, 2011, 2010, 2009, 2007, 2008 22.3% 12.1% 8.4% 4% Others Durango Aguascalientes Source: SE, January 2014 Variation of Mexican mining production of metallic minerals as an annual % change, 2007-12 60% Iron production by state, 2012 27.2% 21.3% Coal 50% 19% Iron 40% Manganeso 30% 14.5% 9.2% 20% 8.8% 10% 0% 10% 2007 2008 2009 2010 2011 2012 20% 30% 40% Source: Statistical Yearbook of the Mexican Mining, 2013, 2012, 2011, 2010, 2009, 2007, 2008 6 Nordic investment in Mexico Source: SE, January 2014 Michoacán Coahuila Colima Others Jalisco Sonora Foreign investment and international trade The Latin American region continues to be one of the most attractive places for mining investment due to its large resource base, especially non-renewable resources. Latin America spent about 25% of the world total (18.2 billion USD) in mineral exploration in 2011. Over the last two decades, the Mexican government has removed several investment requirements and created a legal framework, e.g. the North American Free Trade Agreement, to encourage investment in the mining industry. The liberalisation of the mining industry resulted in an increase of investment in that area. Mexico moved up two positions to be placed fourth in the investment in the world, behind Australia and the United States and it is the first in Latin America for mining exploration investment. According to Economics Metals Group (MEG), Mexico received 6% of global investment in 2010. Companies belonging to the Mexican Mining Chamber (CAMIMEX) have reaffirmed their commitment to the country and announced additional new investment of $7 thousand 647 million dollars for 2012, thus exceeding the $25 thousand million dollars accumulated in the 2007-2012 period. As stated previously, legislation in Mexico has undergone some adjustment over the last two decades. According to this framework, foreign companies wishing to enter the mining industry must register a Mexican corporation or enter into joint ventures with a local entity or partner. The composition of foreign participation in exploration and production in Mexico in 2012 is shown in the Figure ‘Investment in exploration in Mexico as a % share’ and in ‘Investment in production in Mexico as a % share’. Private investment in the Mexican mining industry in million USD, 2006-12 4,720 % 100 90 3,656 80 Value, million USD 5,000 4,561 3,316 70 60 2,858 50 40 30 1,923 2,156 4,000 3,500 3,000 Others 2,500 Environment 2,000 Acquisition and replacement of equipment 1,500 Increasing the capacity and efficiency of operation 20 1,000 10 500 0 2006 2007 2008 2009 2010 2011 2012 0 New Projects Foreign Investment Foreign Investment Total Note(s): (19), (20) See the Table Notes section Source: Statistical Yearbook on the Mexican Mining, 2012 Investment in exploration in Mexico as a % share Investment in production in Mexico as a % share Foreign 60% Foreign 70% Mexican 40% Mexican 30% Source: CAMIMEX. Source: CAMIMEX. PwC Mexico 7 Technology development Suppliers in the mining industry include producers of mining and production equipment, IT providers, and also suppliers of raw materials such as the iron ore, coal and coke needed for the production of steel. Although the majority of companies rely on raw material producers, many are highly vertically integrated and provide their own raw material. Mining equipment According to Business Sweden, there were a total of 174 mining equipment suppliers in Mexico in 2011 and more than 90% of the machinery was imported. Local manufacturers focus on providing parts for conveyor belts, sieves, stone crushers and grinding equipment. Business Sweden states that mining companies like Grupo Mexico, Industrias Peñoles, Empresas Frisco, Minera Autlan and Grupo Acerero del Norte represent around 80% percent of equipment demand, with the remaining 20% coming from over 500 small and mid-sized mining companies. Technological advances in metallurgical mining industry in Mexico, 1530 -1970 1555 1800 Amalgamation with mercury Use of tequesquite was discovered in smelting 1676 1800 Poweruse The first big pumps for dewater were used 1530 Animal use 1530 1570 1610 1650 Source: Peñoles 8 Nordic investment in Mexico 1690 1895-1910 Air drilling: Pachuca tank communication & Silver-Gold electrolysis; Sulphur flotation 1821-1840 1860-1900 Steam pumps were introduced; Use of other steam machines Grinding balls; Crushing machine; Carbide lamp & dynamite 1940 Acidlixiviation Process 1947-1970 Electriclamp; Hidraulic drilling 1800 Scoop tram 1790 1890-1900 1970-1980 Man was substituted by animal in amalgamation Railroad; Electric energy Computation; Satellite 1690 1770 1810 1850 1890 1930 1970 Tools & Equipments Services Modern trends in the Mexican mining industry There is growing demand for robotics and underground excavators among mining companies in Mexico. Digitalisation and satellite images are widely used by companies in Mexico in order to spot ore reserves. The biotic-bioleaching process is now used in Mexico to extract the specific metals i.e. gold and copper from ore. Modern development and future trends in the global mining industry •Tele-operation •Autonomous trucks & shovels •Rapid excavation •Process integration – mine to mill, mill to mine •Mining and remediation with plants Infrastructure Mexican President Enrique Peña Nieto has announced the National Infrastructure Programme (NIP), which is expected to guide the nation’s development plans for the next six years. According to the programme, the government of Mexico will invest several billion USD in its infrastructure and seek private funding to finance the new plan. A notable increase is forecasted in investment in railways while roads and bridges, airports and ports will see only marginal decline. Although public investment is expected to slow, private investment should pick up. As a result, growth is expected to decline to 4.1% per year from 2013 to 2016. In 2011, the predominant mode of transport for Mexican mining exports and imports was charter transport, with 55.25% of total export value and 50.84% of total import value, respectively. Therefore, due to high dependence of the mining industry on infrastructure, mining companies invest in road construction and improvement of utilities. PwC Mexico 9 Mining Legislation Investing in Mining Investment in the mining sector worldwide has increased dramatically in recent years, and as long as high prices in minerals and precious metals remain at currents levels, investments in this sector will continue this tendency, including Mexico. Mexico has a long mining tradition. The territory holds vast wealth and a high potential for mineral resources, which makes it imperative to promote government policies, programmes and actions as well as sound business practices focused on sustainable development and corporate social responsibility, so that those resources can be exploited in a comprehensive and sustainable manner for the benefit of the nation and of the regions in which the deposits are found, thus contributing to well-being of the community and job generation. Currently a new Mining Law is being reviewed by the executive legislators and will be presented and discussed with the legislative representatives. This topic is included in the ordinary sessions from February to April 2014. In order to orient investors in the mining sector, the following are the most usual and important legal procedures involved: 1. Mining concessions A mining concession confers no rights to the surface of the land, but only to concessionable mineral resources in the terms of the Mining Law. Therefore, in order to conduct exploration and exploitation work, the concession holder must establish a private agreement with the owner of the land surface, or, when applicable, request and receive a temporary occupation resolution from the Department of Economy, pertaining to the land surface required for its operations, or from the Agrarian Reform in the case of expropriated communal land. Mining concessions give the concession holder the right to explore, exploit and process concessionable substances located within the mining lot covered. Fifty-year mining concessions have been issued since 2006, renewable for another 50 years. Likewise, coal gas can be exploited, once the holder of a concession to a coal lot has secured the respective permits and authorizations from the Department of Energy. Current mining legislation comprises the Mining Law and the Regulations thereto, the Manual For Mining Services to the Public and the Instructions for Mining Agents, as well as the forms for the procedures required to be carried out at the Department of Economy. With regard to the payment of mining rights, The Law of Government Fees and Duties is applicable to the regulations pertaining to mining procedures. Some of the most important mining procedures are: •The request for a Mining Concession or Assignment and the reduction, division and unification of any titles issued in that regard. •The request to participate in a Bidding Process for awarding a concession. •The request to desist from holding a Mining Concession or Assignment, as well as requests and promotions in process. •The request to register acts, contracts and agreements involving the transfer of ownership of Mining Concessions or the respective rights. •The notification of the beginning of operations for processing ore or concessionable substances. •Obtaining temporary occupation or creating an easement of the indispensable land for conducting the ore exploration, exploitation and processing work. •Reporting and demonstrating execution of the exploration or exploitation work on mining lots. •The request for annulment, suspension or repeal of rights to mining lots. The latter must be submitted to the General Office of Mines. 10 Nordic investment in Mexico 2. Foreign Investment In Mexico, the legal framework that regulates investment by non-Mexican individuals or entities is the Foreign Investment Law (FIL), with a purpose of establishing and regulating the activities in which those individuals or entities are allowed to participate; it assigns percentages, limits, restrictions or conditions for percentages of participation. 3. Permits for the acquisition of real property The acquisition of real property, the exploitation of mines and water and the creation of trusts by foreigners must be registered at the National Foreign Investment Registry. Registration must be carried out within 40 business days as from the date of incorporation of the company or acquisition of an interest in foreign investment, from the date of certification of the documents pertaining to the foreign company, or from the date on which the respective trust is created or trust beneficiary rights are granted to the foreign investor. 4. Environmental procedures The exploration, exploitation and processing of ore and substances reserved for the Federation in the terms of the Mining Law, are subject to evaluation of the environmental impact and the procedure for changing land use. It should be pointed out that mining prospecting is exempt from the procedure; NOM-120SEMARNAT-1977 is applicable to direct mining exploration and can be applicable to that stage, provided the work is in line with the parameters established therein; otherwise, a Preventive Report must be filed at the Department of the Environment and Natural Resources. When the mining project is in the exploitation phase (with or without the installation of ore processing), the head of the project must submit a Manifestation of Environmental Impact, which, depending on the nature of the project, may also require a Risk Study. When mining activities are to be carried out within the buffer zone adjacent to some Protected Natural Area, there are changes in the procedures to be followed, basically concerning the importance of minimising the environmental impact and important restrictions on activities within those zones. In that case, the National Commission for Protected Natural Areas of that same Department must be considered. 5. Land-use rights As mentioned, a mining concession confers no rights to the surface of the land, but only to the mineral resources in the subsoil. Therefore, in order to conduct exploration and exploitation work, the concession holder must establish a private agreement with the owner of the land surface, or, when applicable, request and receive a temporary occupation resolution from the Department of Economy, pertaining to the land surface required for its operations, or from the Agrarian Reform in the case of temporary occupation or easement of expropriated communal land. When communal land is used, the National Agrarian Registry controls the holding of communal land and provides documentary juridical security derived from application of the Agrarian Law, which may make it necessary to carry out formal procedures at that Agency. PwC Mexico 11 6. Water usage Water use is subject to the National Water Law, to the Federal Law of Government Fees, Levies and Duties and to an environmental impact evaluation by the Department of Environment and Natural Resources. The respective concession rights must be secured and water dues must be paid for each type of assignment or concession issued to exploit, use or process national waters, including registration. In the case of residual water discharge, payment must be made for each permit for the discharge of residual water from industrial processes to a receiving body, including registration. 7. Use of explosives The following permits for the use of explosives must be secured from the Defense Department: •The general permit for the purchase, storage and consumption of explosive materials for the mining industry. •The general permit for the purchase and consumption of explosive materials for the mining industry. Recognition of the Legal Representative, as well as any change in same designated by the holder of the General Permit. The user must request approval for the security and location of sites for consumption, as per the official model signed by the Municipal President (one for each consumption site), for the work area in which explosives are to be used, and must request an inspection by the respective Military Zone. As concerns references to the consumption site, “Protection barrier” means any natural land elevation, artificial wall no less than 1 m wide constructed of earth, adobe or sacks of sand, or a forest of a density such that the surrounding areas requiring protection cannot be seen from the site at which explosives are to be consumed, even when the trees are leafless. The State Civil Protection must be requested to secure a favourable opinion from the Governor of the State. Once approval has been secured from the Governor and from Civil Protection and a plan has been prepared specifying the infrastructure of the site for the use, handling and storage of explosives, that approval is sent to Mexico City for the Defense Department, through the General Office of Firearm Registration and Control of Explosives, to analyse the request and issue authorization for the purchase from suppliers, following an inspection visit by the Military Zone. 8. Exploitation of gas in coal mines The Mining Law specifies that mining concessions confer the right to secure a permit from the Energy Department for the recovery and exploitation of coal gas and that the holders of concessions to coal deposits may associate to recover, self-consume and exploit gas associated with carbon deposits, once authorization has been secured from the Energy Department. For that purpose, the following permits must be secured from the Department of the Economy: •A permit for the recovery and exploitation of gas associated with coal deposits. •Authorization to associate for the recovery and exploitation of gas associated with coal deposits, as well as the type of files and documentation attached to both requests. 9. Company incorporation The process of incorporating a company begins with the permit issued by the Department of Foreign Affairs. Once that has been secured, a notary public or official appraiser must certify the charter of incorporation within the following ninety days. The Department of Foreign Affairs must be notified of the use of the permit within the six-month period following issuance. That notification must specify that the charter of incorporation includes a clause excluding foreigners, or specifying that current or future foreign partners must agree to be considered by the Department of Foreign Affairs to qualify as Mexican nationals as concerns all shares, equity units or rights acquired pertaining to the company, and all goods, rights, concessions or interest held by them in the company and all rights and obligations arising from the contracts entered into by the company. Likewise, it must include a statement waiving the protection of their governments; otherwise, the penalty is the forefit of all rights and goods acquired, in favour of the Nation. 12 Nordic investment in Mexico Conclusion While 2013 was a tough year for miners, the industry is positioning itself for a time, hopefully in the not too-distant future, when fundamentals will improve. Still, luring investors back into the mining sector will require strict cost management strategies and responsible investment in production growth. Miners are already heading in the right direction in both fronts. We believe the long-term fundamentals supporting metal prices remain strong and will help to drive the industry’s turnaround. While gold, silver and copper may not reach record levels in the near future, we expect prices to increase, alongside a stabilising global economy6. After all, it’s called a mining cycle for a reason. 6 Source: PwC Gold, Mining and Copper report 2014. PwC Mexico 13 © 2014 PricewaterhouseCoopers, S.C. All rights reserved. PwC refers to the Mexico member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/mx for further details. MPC: 041404_GM_Mining This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors. 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