Mineco crushes nickel ore underground in its mine. Opco, which operates a bulk ore hauling business in Canada, uses a mobile crushing plant (the Mobile Plant) to reduce the size of the ore pieces to a size suitable for processing in the processing plant (Mill) through the “Second Crushing,” with the ore being transported by truck or conveyor to the Mill.
CRA indicated that the Second Crushing activity would be excluded from the definition of "manufacturing or processing" “since it would be the ‘processing’ of ore from mineral resources located in Canada to a stage that is not beyond the prime metal stage or its equivalent.”