Jurisdictional comparison table

CRITERIA
AUSTRALIA
NEW ZEALAND
CANADA
UNITED KINGDOM
SINGAPORE
'Precious metal' definition
  • Type
  • Fineness
Gold (99.5% fineness)
Silver (99.9% fineness)
Platinum (99% fineness)
Gold (99.5% fineness)
Silver (99.9% fineness)
Platinum (99% fineness)
Gold (99.5% fineness)
Silver (99.9% fineness)
Platinum (99.5% fineness)
'Investment gold' refers to:
  • gold (99.5%)
  • gold (post-1800)

90% purity in/was legal tender in country of origin and price <180% spot price.

Gold (99.5% fineness)
Silver (99.9% fineness)
Platinum (99% fineness)
Form requirements
Required to be in an ‘investment form’ – in bar/wafer/coin, bears hallmark guaranteeing fineness and traded by reference to spot price. Any form In the form of a bar, ingot or wafer that must generally be recognized and accepted for trading on Canadian financial markets.
Coins: issued by a government authority and that may be used as currency will qualify.
Bar or wafer or a weight accepted by the billion markets.
A coin that satisfies the legislative requirements.
Must be in a bar, ingot or wafer and possess ‘investment characteristics’.
Coins must be listed in the GST Act to obtain concessional treatment.
GST-free /
Zero-rating
GST-free on the first supply from refiner to dealers, input taxed on subsequent supplies. GST–free on the first supply providing it is an ‘investment item’. the first sale of newly refined precious metal by the refiner or its owner is zero-rated
(GST-free).
GST-free if acquisition is between Central Banks, or between a Central bank and LBMA member, or between LBMA members. None
Input taxed /
GST-exempt
All subsequent supplies of ‘precious metals’ are input taxed. All subsequent supplies of ‘precious metals’ are input taxed in ‘any form’ only. Same as Australia All transactions of investment gold are GST-exempt (unless it already meets GST-free requirements). Supply of ‘investment precious metal’ (IPM) are generally
GST-exempt
(that is, meets the purity, form and accreditation requirements).
Taxable
Gold/silver/platinum that do not meet the definition of ‘precious metal’ are taxable (for example, alloy gold, not in investment form etc.) Same as Australia Same as Australia Gold that are not GST-free or GST-exempt would be taxable. Supplies of metals that do not meet the ‘investment precious metal’ definition are taxable.
Accreditation of refiners No accreditation is required. None Any person who in the regular course of business converts or refines gold, platinum or silver regardless of the degree of purity. LBMA accreditation required (unless the party is a Central Bank). LBMA accreditation
LLPM accreditation
Intends to be LBMA/LLPM accredited and endorsed by International Enterprise Singapore Board.
Special rules on second-hand goods
ITCs for acquisitions of second hand goods from unregistered entities for purposes of sale or exchange. ITC not available for second-hand precious metal from unregistered dealers, but this is currently under review. No ITCs available for acquisition of used goods after April 23, 1996 No special rule on acquisition of second hand precious metal. No special rule on acquisition of second hand precious metal.
Gold-bullion specific invoicing requirements
None None None None Yes - IPM traders must supply within 30 days an invoice which names the supplier. The purchaser type of precious metal, weight, purity name of refiner, unique serial number, name and weight of coin, weight, total amount payable, etc.
Registration /
Notification /
Reporting requirements to revenue authority
None – no requirement to notify ATO of precious metal transactions. None None HMRC needs to be notified within 28 days of making the first exempt supply of investment gold > £5,000 (or 12mth period > £10,000) (applies to both VAT-registered and non-registered entities). This is a one-off notification. In order to access
GST-exemption for investment precious metal, the entity must be an Approved Refiner and Consolidator Scheme (ARCS) entity.

Source: ATO