TitanForge — Financial Plan — Assumptions & Methodology

The financial plan assumptions and methodology, including the South African fiscal regime and unmodelled conservatism underpinning TitanForge.

TitanForge Business PlanSection 20 › Financial Plan — Assumptions & Methodology

Section 20 · Business Plan

Financial Plan — Assumptions & Methodology

The financial plan assumptions and methodology, including the South African fiscal regime and unmodelled conservatism underpinning TitanForge.

The financial plan applies an honest-analyst methodology. Sponsor
anchors, revenue, EBITDA and the division mix, are preserved exactly as
provided. Every line below EBITDA is independently re-derived from first
principles:

  • Depreciation: per-vintage straight-line on each
    project at its asset life (mining 18–20 years, rail/port/energy 25
    years, industrial park 22 years), half-year convention in the
    commissioning year, plus the R24bn opening asset base over 15 years and
    sustaining capex over 12 years. The charge grows from R1.9bn in Year 1
    to R8.6bn in Year 10.
  • Interest: full cash interest on opening facility
    balances plus half-year interest on in-year draws, at the
    facility-specific rates in Section 15.1. No interest during construction
    is capitalised. The charge peaks at R3.6bn in Year 5.
  • Taxation: 27% South African corporate rate;
    section 20 assessed-loss carry-forward applied with the
    80%-of-taxable-income utilisation cap. The Group is profitable from Year
    1 at the PBT line, so no assessed losses accumulate in the base case,
    but the mechanism is modelled and would engage automatically in the
    downside.
  • Working capital: 9.0% of revenue, with the
    year-on-year movement charged against operating cash flow.
  • Dividends: 35% of net profit once net
    debt/EBITDA is below 2.0x (from Year 4), stepping to 55% from Year 7,
    always subject to a R1.5bn minimum cash floor.
  • Balance sheet integrity: assets minus
    liabilities-plus-equity is programmatically asserted to equal zero in
    every forecast year; the model does not produce output if any year
    fails.

16.1 South African fiscal regime and unmodelled conservatism

The plan taxes profits at the statutory 27% on accounting profit
before tax, with the section 20 assessed-loss mechanism. The actual
South African fiscal regime for this asset class contains several
provisions the model deliberately does not exploit, each of which would
improve early-year cash flow if claimed:

  • Section 36 mining capital redemption: qualifying
    mining capex is deductible against mining income as incurred (subject to
    ring-fencing per mine). Applied to Iron Crown’s R18bn, this alone would
    shelter most mining taxable income in Years 1–5, deferring an estimated
    R3–5bn of cash tax into later years.
  • Sections 12B/12BA renewable allowances:
    accelerated (and temporarily 125%) deductions for renewable generation
    assets would shelter Helios income substantially in its first
    years.
  • Section 12F/rolling-stock allowances and SEZ
    incentives:
    port and rail asset allowances, and the 15% SEZ
    rate for qualifying Forge Park activities, are similarly
    excluded.
  • Mineral royalties: MPRRA royalties (0.5–7% of
    gross sales on a profitability-linked formula, refined vs unrefined) are
    treated as embedded within the sponsor’s EBITDA operating costs rather
    than added below the line — consistent with preserving the sponsor
    anchor, and disclosed here so lenders can test it in due
    diligence.
  • Carbon tax: phase 2 carbon tax on process and
    combustion emissions is assumed absorbed within operating costs,
    partially offset by Helios displacement of grid electricity.
Why the tax conservatism matters

Modelling full 27% cash tax without capital allowances overstates
early tax by an estimated R4–6bn cumulatively over Years 1–5 — which
means the sub-1.0x DSCR findings in Section 19 are, if anything, harsher
than reality. A tax structuring workstream at financial close (mining
ring-fence elections, s36 scheduling, 12B claims) is a genuine value
lever that costs little and directly repairs the plan’s weakest years.
It is presented as upside precisely because bankability should not
depend on it.

Confidential — this business plan is provided to prospective investors and lenders for evaluation purposes only and may not be reproduced or distributed without the written consent of TitanForge Resources & Infrastructure Holdings.