C. IncentivesThe Mining Investments Law No. 24,196, regulated by Administrative Order No. 2,686/93, sets forth a series of benefits forcompanies that carry out mining activities not related to oil and gas and are registered with the Mining Investments Registry.These include the following:► Total tax burden stability for 30 years, which is determined upon presentation of the feasibility study — this provision doesnot include VAT, which will be subject to the general tax treatment. The tax stability will also be applicable to foreignexchange and tariff systems, excluding the foreign exchange parity and export tax rebates, refunds and/or reimbursements(refer below).► Double income tax deduction of all the amounts invested in prospect, exploration, special studies, mineralogical andmetallurgical assays, pilot plant and other work intended to determine the technical and economic feasibility of projects;exploration fees are not included as a deductible expense.► Income tax exemption regarding income from mining contributions and rights, such as capital stock, in companies engaged inperforming the activities regulated by this system. This applies if the contributor and beneficiary companies keep thecontribution in their related equity for a term of at least five consecutive years.► Accelerated amortization system for income tax purposes of capital investments incurred in executing new mining projectsand expanding the existing ones (refer below).► Exemption from the payment of customs duties related to the entry of capital goods, special equipment or components ofsuch assets or of the inputs determined by the enforcement agency, as required to undertake the activities regulated by thissystem (refers to Section H).► System to request VAT credits resulting from imports and purchases of goods and services intended for use in miningactivities: prospecting, exploration, metallurgical assays and applied research (refer to Section H).► The companies may book a provision for environmental expenses, which may be deducted from the income tax assessment.The latter may not exceed 5% of extraction and benefit operating costs.Tax stabilityInvestments in new mining projects and in extending the existing ones, protected by Law No. 24,196, benefit from the taxstability for a 30-year term as from the date when the feasibility study is filed.Tax stability means that companies’ tax burden, as determined at the time of filing the feasibility study, cannot be increased as aresult of changes in federal, provincial or municipal taxes and rates. The tax stability regime is applicable to all taxes that thecompanies registered are subject to, as well as the duties, tariffs or other taxes on imports or exports.The total tax burden in each tax-related area may rise because of the below factors, as long as their effects are not compensatedin that same jurisdiction through abolishing or reducing other taxes or tax regulation amendments favorable to the taxpayer:► Creation of new taxes► Increase in rates or amounts► Change in the mechanism or proceedings in assessing a certain tax base, whereby different guidelines or conditions areestablished than those established when the beneficiary filed its feasibility study and which entail an increase in the tax baseOn the other hand, the following situations shall not be covered by the tax stability or shall not violate such tax stability:► Changes in the valuation of assets, when such valuation forms the base for the tax’s application and assessment► Extension for a specified period of time of the validity of enacted regulations that are enforced upon obtaining thetax stability► Defeasance of exemptions, exceptions or other measures applicable for a given period and that such defeasance results fromthe expiration of such a period► Employer and employee contributions to the Single Social Security System and indirect taxes
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