Seabridge Gold has successfully challenged a Canada Revenue Agency decision that disallowed $15.8 million in exploration expenses.

The B.C. Supreme Court ruled the company鈥檚 work qualified for tax credits under provincial mining legislation.

鈥淚 am very pleased with the BCSC decision validating Seabridge鈥檚 claimed expenditures. It demonstrates that our approach to claiming expenses under BC METC and in respect of flow-through share subscriptions has been reasonable,鈥� said Rudi Fronk, Seabridge chairman and CEO.

At the heart of the case was $3.1 million in tax refunds plus interest, under the B.C. Mining Exploration Tax Credit (BC METC) program. The court awarded Seabridge the full amount, along with its appeal costs.

Justice Miriam Maisonville found that a wide range of technical and engineering activites undertaken by the company 鈥� such as mine design, geotechnical and water engineering, metallurgical analysis, infrastructure planning, and tailings management鈥攎et the statutory test of being incurred to determine the existence, location, extent or quality of a mineral resource in the province.

The only expenses she ruled ineligible were those tied to preparing a pre-feasibility report.

The ruling also carries potential implications for a separate federal tax matter involving Seabridge鈥檚 flow-through shares between 2013 and 2015. The company had claimed similar expenditures as 鈥淐anadian exploration expenses鈥� under the federal Income Tax Act. However, after reassessing those filings, the CRA reduced the amount renounced to investors by roughly $19.1 million, disallowing related deductions and credits.

Seabridge has objected to the federal reassessment and deposited $9.4 million with the CRA on behalf of the affected investors. The company stated it believes the B.C. court鈥檚 decision may have a bearing on the federal dispute and will be reviewing next steps with legal counsel.