Australia → Hong Kong (China SAR) → United Kingdom · Retail investment-gold sale by a dealer (HVD rules for cash)

Public law and official guidance, published as research. Not legal, tax or financial advice.

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Australia (Doré bar - unstamped → 999.9 kilobar) ⟶ Hong Kong SAR China (999.9 kilobar) ⟶ United Kingdom (999.9 kilobar)

Not researched: Hong Kong SAR China → United Kingdom

Leg 1: Australia

Where the goods start

Doré bar - unstamped → 999.9 kilobar

1
Enrol with AUSTRAC within 28 days of starting a designated service and adopt an AML/CTF program (bullion dealing; from 31 Mar 2026 also buying or selling precious metal for $10,000 or more in physical currency or virtual assets, with obligations from 1 Jul 2026)
Who
Bullion dealer / dealer in precious metal
Issues
AUSTRAC enrolment; AML/CTF program
Primary law
- AML/CTF Act 2006, s.6(3) table 2 items 1-2; ss.26B, 51B
  “buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products”
2
Carry out customer due diligence before providing the designated service; enhanced due diligence in higher-risk cases
Who
Bullion dealer / dealer in precious metal
Needs
AUSTRAC enrolment
Issues
Customer due diligence file
Primary law
- AML/CTF Act 2006, s.28 (initial CDD); s.39E item 11 (bullion under $5,000)
  “A reporting entity must not commence to provide a designated service to a customer if the reporting entity has not established on reasonable grounds each of the matters in subsection (2)”
3
Sell or buy bars: input-taxed supply of precious metal (no GST charged, no input credits), or GST-free if it is the refiner's first supply after refining to a dealer
Who
Bullion dealer / dealer in precious metal
Needs
Customer due diligence file
Issues
Commercial invoice (GST-free / input-taxed treatment stated)
Primary law
- A New Tax System (Goods and Services Tax) Act 1999, s.40-100; s.38-385
4
Report each threshold transaction (transfer of $10,000 or more in physical currency) to AUSTRAC within 10 business days
Who
Bullion dealer / dealer in precious metal
Issues
Threshold transaction report
Primary law
- AML/CTF Act 2006, s.43; s.5 threshold transaction
5
Report suspicious matters to AUSTRAC (within 3 business days, or 24 hours for terrorism financing suspicions)
Who
Bullion dealer / dealer in precious metal
Issues
Suspicious matter report
Primary law
- AML/CTF Act 2006, s.41
6
Hold a granted mining lease (or state equivalent) with approvals to mine
Who
Mining tenement holder (mining lease) operating a gold mine and mill
Needs
Mining lease
Primary law
[not-read] Mining proposal and closure plan approvals not read.
- Mining Act 1978 (WA), ss.71, 78, 85
7
Mine ore, process (CIL/gravity), and pour doré bars at the mine site; mark each bar
Who
Mining tenement holder (mining lease) operating a gold mine and mill
Issues
Mine doré bar number and mine mark
Form
Ore (in situ / run-of-mine) → Doré bar - unstamped
Industry practice
Mine-site processing described only generally.
8
Collect doré under secure transport and deliver to the refinery
Who
Secure precious-metals carrier / airline
Needs
Refining (toll) agreement between miner and refiner
Industry practice
9
Receive, weigh and sample the doré; issue receipt. For WA royalty, gold metal is taken to be produced on delivery to the refinery if delivered within 3 months of the gold-bearing material being obtained; otherwise on the day after the 3-month period
Who
Australian gold refiner (LBMA Good Delivery-listed)
Issues
Refinery receipt and weigh-in of doré
Primary law
- Mining (Royalties) Regulations 2025 (WA), rr. 29, 31-32
10
Assay the doré and issue the outturn statement; credit the miner's metal account with fine gold (or buy the gold outright)
Who
Australian gold refiner (LBMA Good Delivery-listed)
Needs
Refinery receipt and weigh-in of doré
Issues
Outturn / assay statement; Metal account statement
Industry practice
11
First sale of refined gold: GST-free where it is the first supply after refining by or on behalf of the supplier, by a refiner of precious metal, to a dealer in precious metal; otherwise the supply of precious metal is input taxed
Who
Mining tenement holder (mining lease) operating a gold mine and mill
Needs
Metal account statement
Issues
Commercial invoice (GST-free / input-taxed treatment stated)
Primary law
[conflict] au.div-gst-scrap (refining from scrap).
- A New Tax System (Goods and Services Tax) Act 1999, s.38-385; s.40-100; s.195-1
12
Prepare commercial invoice and bar list; no export permit or licence is required for gold
Who
Exporter of bars (refiner, dealer or miner selling offshore)
Needs
Bar list for refined bars
Issues
Commercial invoice (GST-free / input-taxed treatment stated)
Primary law
[inferred] Absence of a gold export permit read from the Regulations as a whole; commercial invoice and bar list are commercial practice.
- Customs (Prohibited Exports) Regulations 1958 (no gold item)
13
Lodge the export declaration in the Integrated Cargo System (required for consignments above $2,000 FOB) and obtain the export entry advice (authority to deal) with its number before loading; a declaration may be refused if the intended export day is more than 6 months ahead; if not exported within 30 days of the intended day, withdraw or amend within 7 days; keep commercial documents 5 years
Who
Licensed customs broker
Needs
Commercial invoice (GST-free / input-taxed treatment stated)
Issues
Export declaration and export entry advice (authority to deal, with export entry advice number)
Primary law
- Customs Act 1901, ss.113, 114, 114C, 116, 240(1A); Customs Regulation 2015 r. 82
  “an FOB value not exceeding $2,000 or such other amount as is prescribed”
14
Obtain a certificate of origin only if the buyer or the destination requires one (e.g. to claim an FTA preference); an exporter claiming Australian origin for a preferential tariff in China, Hong Kong or the UK may be required by the ABF to produce origin records and answer questions for verification by the importing customs
Who
Exporter of bars (refiner, dealer or miner selling offshore)
Issues
Certificate of origin (on request)
Primary law
[not-read] Issuing bodies and forms for certificates of origin not researched (au.gap-cert-origin); no Australian export rule requires one for gold.
- Customs Act 1901, Divisions 4J, 4K, 4M (ss.126AOA-126AOD, 126APA-126APD, 126ARA-126ARD)
15
Ship by secure air freight under air waybill
Who
Secure precious-metals carrier / airline
Needs
Export declaration and export entry advice (authority to deal, with export entry advice number)
Issues
Air waybill
Industry practice
Carrier practice not documented in the sources read.

Taxes and fees

Export duty on gold
None All exports, including gold
Official guidanceAmount not confirmed
NSW gold royalty
4% of ex-mine value
Official guidanceAmount not confirmed
- Mining Act 1992 (NSW)
Queensland gold royalty
2.5% of value if the average market price for the return period is at or below A$600/oz (reference price 1); 5% if at or above A$890/oz (reference price 2); in between 2.5 + (PD/RFD) x 2.5 per cent, rounded down to 0.02%
Primary lawAmount not confirmed
- Mineral Resources (Royalty) Regulation 2025 (Qld), s.22; s.26; Sch 1 Pt 1 ss.1-2
Victorian gold royalty
2.75%
Primary lawAmount not confirmed
- Mineral Resources (Sustainable Development) (Mineral Industries) Regulations 2019 (Vic), regs 4, 5, 6(1A)-(1B), 8, 74
WA gold royalty (Mining Regulations 1981)
2.5%
Primary lawAmount not confirmed
- Mining Regulations 1981 (WA), r. 86AA(1), (4), (6), (7)
WA gold royalty
2.5% Gold metal (at least 99.5% pure) taken to be produced on delivery of gold-bearing material to a refinery within 3 months of extraction (r. 31), otherwise on the day after the 3-month refining period (r. 32), or, for gold-bearing material exported as concentrate or crushed/screened material, when the ship arrives at the unloading place (r. 33)
Primary lawAmount not confirmed
- Mining (Royalties) Regulations 2025 (WA), rr. 9, 10, 13(2)(a), 14, 21, 22, 30-33; Sch 1 Div 2

Controls

Buying or selling bullion (gold, silver, platinum or palladium as a bar, coin, ingot, plate, wafer or like form, bearing a mark guaranteeing fineness and traded by reference to the spot price) in the course of carrying on a bullion-dealing business is a designated service: enrolment, AML/CTF program…
Primary law
- AML/CTF Act 2006, s.5 (bullion); s.6(3) table 2 item 1; ss.39E, 41, 43, 51B
Buying or selling precious metal (gold, silver, platinum-group metals, or an alloy with at least 2% of them, manufactured or not), precious stones or precious products in the course of carrying on a business, where the purchase involves physical currency and/or virtual assets totalling $10,000 or mo…
$10,000 in physical currency and/or virtual assets
Primary law
- AML/CTF Act 2006 as amended by the AML/CTF Amendment Act 2024, s.5A; s.6(3) table 2 item 2; Amendment Act s.2 and Sch 3 Pt 4 items 11-12
  “buying or selling one or more of the following items in the course of carrying on a business, where the purchase involves the transfer of physical currency or virtual assets (or a combination of physical currency and virtual assets) with a total value of not less than $10,000, whether the purchase is made in a single transaction or in several transactions that are linked or appear to be linked: (a) precious metal; (b) precious stones; (c) precious products”
Export markets accept Australian bars through the refiner's LBMA Good Delivery listing and exchange accreditations (CME, SGE, OSE, DGCX for the Perth Mint).
Industry practice
No economy-wide cap on cash payments was found. Reporting entities must report threshold transactions (transfers of $10,000 or more in physical currency) to AUSTRAC within 10 business days (s.43; s.5). Moving monetary instruments worth $10,000 or more into or out of Australia must be reported (s.53)…
$10,000 (reporting, not a limit)
Primary law
- AML/CTF Act 2006, ss.5, 43, 53
  “monetary instrument means any of the following: (a) physical currency; (b) a bearer negotiable instrument; (c) a thing prescribed by the AML/CTF Rules.”
No foreign-exchange control or repatriation requirement on gold export proceeds was identified.
Unverified
No export permit or licence for gold (it is not a prohibited export). The owner must enter goods for export by an export declaration and may not load them without an authority to deal (export entry advice); consignments with an FOB value of $2,000 or less are exempt unless a permission is required. …
FOB value above $2,000
Primary law
- Customs Act 1901, ss.113(1)-(2A), 113AA, 114, 114C, 116
  “an FOB value not exceeding $2,000 or such other amount as is prescribed”
Origin and CAHRA due diligence on supplies is imposed on Australian refiners by the LBMA RGG as a Good Delivery condition, not by Australian statute.
Secondary
Importing, purchasing or transporting gold (HS 7108) that was exported from Russia after 30 Sep 2022 is a sanctioned import (Designation Sch 1 item 16; AS Regulations reg 4A(1)-(3)) and an offence unless authorised by a permit of the Minister for Foreign Affairs under reg 18(1)(b) (reg 12A); it exte…
Primary law
- Autonomous Sanctions (Import Sanctioned Goods-Russia) Designation 2022 Sch 1 item 16; Autonomous Sanctions Regulations 2011 regs 4A, 12A, 18; Autonomous Sanctions Act 2011 s.16
Supplying, selling or transferring an item of gold, precious metals and diamonds so that it is transferred to the Government of Syria (or its public bodies, agents or controlled entities) is a sanctioned supply, and importing or purchasing such an item from them is a sanctioned import; both are offe…
Primary law
- Autonomous Sanctions Regulations 2011, regs 4(4), 4A(4), 12, 12A, 18

Leg 2: Hong Kong SAR China

On the way

16
Onboard the supplier: KYC and source-of-supply review. Hong Kong law makes CDD mandatory for a Category B registrant only for specified cash transactions (AMLO s.5A(5A)); for bank-paid purchases the pack is the importer's own risk choice, with LBMA/OECD guidance applying where the buyer or refiner is bound by it
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
DPMS Category A registration certificate; Commercial invoice
Issues
Supplier KYC pack held by the Hong Kong importer; Customer due diligence file (Category B, specified cash transaction); Supplier's commercial invoice
Official guidance
[inferred] No Hong Kong rule found that requires origin documents for imported gold; the KYC pack is commercial practice outside cash transactions. The legal scope of CDD is read in the Ordinance.
- AMLO s. 5A and Sch. 2 (only for specified cash transactions), s. 5A(5A)-(5B)
  “An AML/CTF requirement that applies to a DNFBP who is a Category B PMS registrant only applies when, by way of business, the registrant carries out, in Hong Kong with a customer, a specified cash transaction that is not an excluded transaction”
17
Fly the consignment into HKIA and deliver it to the importer's vault. If it is transhipment cargo (consigned on a through bill of lading or through air waybill to a place outside Hong Kong) or transit cargo, no Hong Kong declaration is required and the gold never enters the Hong Kong market
Who
Secure logistics carrier / forwarder
Needs
Supplier's commercial invoice; Air waybill; Export customs declaration accepted by the dispatching country's customs
Issues
Inbound air waybill
Primary law
- Import and Export (Registration) Regulations (Cap. 60E), reg. 3(a)-(b); Cap. 60 s. 2 (transhipment cargo, article in transit)
18
Receive the bars, weigh them and check serials against the bar list; credit the importer's allocated account
Who
Precious-metals vault operator
Needs
Inbound air waybill
Issues
Weight and quality verification record; Bar list (serials, weights, fineness); Allocated account weight list
Industry practice
[inferred] Vault intake practice is not documented in an official source; the clearing press release confirms designated vaults record deposits.
19
Lodge the import declaration within 14 days after the day of importation using the specified system (Trade Single Window, or during the transition a government-appointed service provider). Gold bars of fineness 995.0 or above (HKHS 7108 1210, 7108 2010) go on Form 1B with no declaration charge; other gold pays the charge. No customs duty or VAT; gold is not an exempted article
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
Inbound air waybill; Supplier's commercial invoice
Issues
Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days)
Primary law
- Import and Export (Registration) Regulations (Cap. 60E), regs 3, 4(1)-(2), 7, 8(1), (1AA), (4), 18
20
If the gold is paid for with physical currency or BNIs above HK$120,000 carried across the boundary, declare the cash (not the gold) to C&ED: advance CDS declaration for cargo, red channel for arriving travellers
Who
Registered bullion dealer / trader (DPMS registrant)
Issues
CBNI advance electronic declaration (CDS) for cash moved as cargo
Primary law
- Cap. 629, ss. 2, 4, 9, 11; Sch. 4
21
Mainland buyer (holder of a PBOC gold import qualification) obtains a PBOC Gold and Gold Products Import/Export Permit for the consignment: one shipment, one permit, used within 40 working days
Who
Mainland importer holding a PBOC gold import qualification
Issues
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证)
Primary law
- PBOC/GACC gold import-export measures, Arts. 3, 8, 17
22
Agree the sale with the Mainland importer and release bars (typically 999.9 kilobars or bank-refined bars) to the cross-boundary carrier
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Allocated account weight list
Issues
Hong Kong exporter's commercial invoice; Packing list; Outbound air waybill / cross-boundary transport document
Official guidance
[unconfirmed] Bar form preferred by the Mainland market not confirmed from an opened source.
23
Lodge the Hong Kong export declaration within 14 days; C&SD records the flow as an export to the Mainland
Who
Registered bullion dealer / trader (DPMS registrant)
Needs
Hong Kong exporter's commercial invoice
Issues
Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days)
Primary law
C&SD FAQ Q1: Hong Kong is a separate customs territory, so a declaration is required for goods exported to the Mainland.
- Import and Export (Registration) Regulations (Cap. 60E), reg. 5(1)-(2)
24
Clear Mainland customs by presenting the PBOC permit, then register the gold on the State Council-approved gold spot exchange and complete its first trade there
Who
Mainland importer holding a PBOC gold import qualification
Needs
PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days); Export customs declaration accepted by the dispatching country's customs
Primary law
This step happens under Mainland law and belongs to the China module; kept here to show the hand-off.
- PBOC/GACC gold import-export measures, Arts. 6, 17

Taxes and fees

Customs duty on gold
Nil All gold imports and exports; the Ordinance applies only to alcoholic liquors, tobacco, aircraft spirit, light diesel oil, motor spirit, kerosene and methyl alcohol (s.3(1))
Primary lawAmount not confirmed
- Dutiable Commodities Ordinance (Cap. 109), ss. 3(1), 4(1)
Profits tax on gold trading profits
Corporations: 8.25% on the first HK$2,000,000 of assessable profits and 16.5% above (Sch. 8B s.2(a)); unincorporated businesses: 7.5% and 15% (Sch. 8A s.2); years of assessment from 1 April 2018 Trading profits of Hong Kong gold dealers; not a transaction tax
Primary lawAmount not confirmed
- Inland Revenue Ordinance (Cap. 112), s. 14; Schs. 8A, 8B
  “Subject to the provisions of this Ordinance, profits tax shall be charged for each year of assessment on every person carrying on a trade, profession or business in Hong Kong in respect of his assessable profits arising in or derived from Hong Kong for that year from such trade, profession or business (excluding profits arising from the sale of capital assets)”
VAT / GST on gold
None (Hong Kong has no VAT or GST) Import and sale of gold
UnverifiedAmount not confirmed
Import/export declaration charge
Nil on declarations relating to gold bars (reg. 8(4)); C&SD defines these as gold bars of fineness 995.0 or above, HKHS codes 7108 1210 and 7108 2010, declared on Forms 1B/2B. Other gold (e.g. dore below 995.0): HK$0.20 for value up to HK$46,000, then 12.5 cents per additional HK$1,000 or part, rounded up to 10 cents, capped at HK$200 per declaration (reg. 8(1)(b)-(d), (1AA)) Each import and export declaration
Primary lawAmount not confirmed
- Import and Export (Registration) Regulations (Cap. 60E), reg. 8(1), (1AA), (4); reg. 7
  “No charge shall be payable under paragraph (1)(b), (c) or (d) in respect of a declaration relating to gold bars within the meaning of the Imports and Exports Classification List”

Controls

A Category B registrant must, before a specified cash transaction (cash of HK$120,000 or more) with a customer, identify and verify the customer and any beneficial owner, obtain the purpose of a business relationship and verify anyone acting for the customer (Sch. 2 ss.2, 3(1)(b)); obtain senior-man…
Cash payment of HK$120,000 or more
Primary law
- AMLO (Cap. 615) s. 5A and Sch. 2; C&ED Guideline for Category B registrants, s. 5A(5A)-(5B); Sch. 2 ss. 2, 3, 5, 10, 15, 19, 20; s. 53ZVF
  “for a period of at least 5 years beginning on the date on which the transaction is completed”
A non-Hong Kong dealer (an individual not ordinarily resident, or a foreign legal person that is neither a registered non-Hong Kong company nor a re-domiciled company; no place of business in Hong Kong; business in Hong Kong on no more than 60 days a year) is outside registration but must report eac…
HK$120,000 cash
Primary lawAmount not confirmed
- AMLO (Cap. 615) Part 5C, ss. 53ZTZ, 53ZUA(2), 53ZVK; Sch. 3J
Any person who knows or suspects that property represents proceeds of, or was or is intended to be used in connection with, an indictable offence (OSCO s.25A(1)) or drug trafficking (DTROP s.25A(1)), or that property is terrorist property (UNATMO s.12(1)), must disclose it to an authorized officer (…
Primary law
- OSCO (Cap. 455), DTROP (Cap. 405), UNATMO (Cap. 575), Cap. 455 s. 25A; Cap. 405 s. 25A; Cap. 575 s. 12
  “Where a person knows or suspects that any property— (a) in whole or in part directly or indirectly represents any person’s proceeds of; (b) was used in connection with; or (c) is intended to be used in connection with, an indictable offence, he shall as soon as it is reasonable for him to do so disclose that knowledge or suspicion … to an authorized officer”
Hong Kong applies only UN Security Council sanctions, through regulations the Chief Executive makes under Cap. 537 on instructions from the Ministry of Foreign Affairs (ss.2-3); dealing with funds or economic resources of designated persons without a licence is an offence under those regulations (C&…
Primary law
- United Nations Sanctions Ordinance (Cap. 537), ss. 2-3
  “the Ministry of Foreign Affairs of the People’s Republic of China”
Currency and bearer negotiable instruments above HK$120,000 (Sch. 4) must be declared by arriving travellers (s.4), disclosed on request by other arrivals and by departing travellers (ss.5-6), and declared in advance electronically when moved as cargo in one batch (ss.9-11). "CBNI" means notes or co…
HK$120,000 of CBNIs
Primary lawAmount not confirmed
- Cap. 629, ss. 2, 4-6, 9-11; Sch. 4
The central clearing system accepts only about-400-oz bars meeting international standards (in effect LBMA Good Delivery) into designated vaults, held unallocated and commingled.
Official guidance
- Clearing Rulebook
No new commodity exchange may be established or operated for gold, silver or the other listed commodities (Cap. 82 s.4 and Schedule items 6, 13; fine HK$500,000 plus HK$50,000 a day), except an exchange "which was in operation on 20 June 1973" (s.3(d)) or a recognized futures market under the Securi…
Primary law
- Commodity Exchanges (Prohibition) Ordinance (Cap. 82), ss. 3(d)-(e), 4; Schedule
  “(e) a recognized futures market”
Anyone who by way of business trades in, imports, exports, manufactures, refines or carries out value-adding work on precious metals (gold "in a manufactured or unmanufactured state"), issues or trades precious-asset-backed instruments, or acts as intermediary (s.53ZU(1)) must be registered before c…
HK$120,000 per transaction or linked transactions
Primary lawAmount not confirmed
- AMLO (Cap. 615) Part 5C, ss. 53ZTZ, 53ZU, 53ZUA, 53ZUE; Schs. 3H, 3I
Only bars from HKGX authorised minters (13 members) are good delivery on the exchange, by type: 99 gold 5-tael, 999.9 gold kilo, 999.9 gold 5-tael and 999.9 silver 15 kg.
Industry practice
- HKGX rules
A Legislative Council question of May 2026 refers to "the current 50-gram limit" on gold products for personal use carried by Mainland visitors, and asks about "simplifying the tax collection process for amounts exceeding the limit"; the limit is a Mainland rule. The Government replied only that Hon…
50 g (per LegCo question; Mainland rule not read)
SecondaryAmount not confirmed
Gold entering the Mainland from Hong Kong under general trade needs a PBOC Gold and Gold Products Import/Export Permit presented to customs (Art. 3), issued only to qualified importers (Art. 8, e.g. financial-institution members or market makers of the State Council-approved gold exchange); "one bat…
Primary law
- PBOC/GACC gold import-export measures (Order [2015] No. 1, amended 2020), Arts. 3, 4, 6, 8, 17, 20
No import or export licence, permit or duty applies to gold. Licences are needed only for articles listed in the regulations under Cap. 60 (s.6C: Cap. 60A Sch. 1; s.6D: Cap. 60A Sch. 2; s.6A: strategic commodities), and gold is not listed in Cap. 60A Schedules 1-2. The only customs formality is the …
Primary law
- Import and Export Ordinance (Cap. 60) and regulations, Cap. 60 ss. 6A, 6C, 6D; Cap. 60A Schs. 1-2; Cap. 60E regs 3-5

Leg 3: United Kingdom

Where the goods arrive

25
Apply customer due diligence to the foreign seller before buying (identity, beneficial owner, purpose, risk assessment, sanctions/PEP screening)
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Issues
Supplier KYC pack received by the UK buyer; MLR customer due diligence file
Primary law
[unconfirmed] Whether a non-bank wholesale bullion trader paid by wire is within the MLR at all (e.g. as a financial institution under reg 10) - consolidated MLR not held. [not-read] Reg 27 quoted via WebFetch; MLR not held.
- Money Laundering Regulations 2017, reg 27
26
Establish that the gold is not Russian-origin gold exported from Russia on or after 21 Jul 2022, not relevant processed gold incorporating such gold, and not Russian gold jewellery exported on or after 29 Oct 2022; check where the goods were originally consigned or exported from; if Russian origin is possible, apply to DBT's Import Sanctions Team for a licence or contact it; declare document code 9022 (not subject to / exempt from sanctions) or 9011 (licence) on CDS and keep the evidence to produce on demand
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
Export customs declaration accepted by the dispatching country's customs
Issues
Importer's Russia-sanctions origin evidence file
Primary law
[inferred] The guidance and tariff do not list specific evidence documents; the required kinds are this module's inference.
- Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850 and SI 2022/1110, regs 46Z11, 46Z16B, 46Z16C
27
Fly the bars into the UK as valuable cargo (typically Heathrow) under an air waybill
Who
Secure valuables carrier
Issues
Air waybill, inbound valuables consignment
Unverified
UK valuables-cargo handling not researched in this pass.
28
Submit a full import declaration on CDS (procedure code, commodity code 7108 12 00 00 for unwrought gold, DUCR, consignor/consignee, value, licences; EORI); declare sanctions document code 9022 or 9011; claim the investment-gold VAT exemption with additional code VATE where the bars are 995+ of a weight accepted by the bullion markets
Who
Customs agent / declarant using CDS software
Needs
EORI number of importer/exporter; Importer's Russia-sanctions origin evidence file; Air waybill, inbound valuables consignment; Air waybill; Commercial invoice; Bar list (serials, weights, fineness)
Issues
CDS full import declaration
Official guidance
[conflict] gb.div-cpc-chief - VAT Notice 701/21 s.8.1 still gives CHIEF CPC 40 00 073; the tariff (28 Sep 2026) shows the exemption as additional code VATE. [not-read] The CDS procedure code and DE 1/10-1/11 entries for investment gold not read (UK Trade Tariff Vol. 3 listed in gb-fetch.tsv).
29
Account for import VAT: exempt for investment gold (additional code VATE); 20% standard rate (code 03020) on non-investment gold (dore, grain, scrap, sub-995 bars, non-qualifying coins); customs duty 0.00% (third-country rate on 7108 12, S.I. 2020/1430)
Who
Bullion dealer / trader (importer of record, usually an LBMA member)
Needs
CDS full import declaration
Official guidance
- VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21, Notice s8.1, s10.7
30
Clear the goods (CDS message when cleared), or ask for supporting documents for a customs check; for 7108 the Russia/Belarus measures read "Import allowed after control"; HMRC enforces trade sanctions at the border
Who
HMRC (customs and VAT authority)
Needs
CDS full import declaration
Issues
CDS clearance notification (goods released)
Official guidance
31
Register with HMRC as a high value dealer before accepting or making any cash payment of GBP 10,000 or more (single or linked); pay annual fee
Who
Retail bullion dealer accepting cash (high value dealer)
Issues
HMRC MLR registration as high value dealer
Primary law
[conflict] gb.div-hvd-guidance-lag. Registration requirement ("must not accept or make a high value cash payment until you have registered") from the HMRC page; the MLR registration regulation not read.
- MLR 2017 as amended by SI 2026/621, reg 14 (definition)
32
Apply CDD to any occasional cash transaction of GBP 10,000 or more
Who
Retail bullion dealer accepting cash (high value dealer)
Needs
HMRC MLR registration as high value dealer
Issues
MLR customer due diligence file
Primary law
[not-read] Reg 27(3) quoted via WebFetch; amount confirmed by SI 2026/621 reg 14(c) (held).
- MLR 2017, reg 27(3)
33
Sell investment gold VAT-exempt to the retail customer: identity evidence (one List 1 and one List 2 document), invoice and records where the thresholds are met
Who
Retail bullion dealer accepting cash (high value dealer)
Needs
MLR customer due diligence file
Issues
Investment gold invoice (VAT tertiary legislation s.3 / VAT Regs reg 31A); Investment gold customer records and identity evidence
Official guidance
- VAT Notice 701/21; VAT Regs 1995 reg 31A, Notice s7.1

Taxes and fees

Customs duty on gold (UK Global Tariff)
0.00% (third-country duty on 7108 12 00 00; preferential rates also 0.00%) HS 7108 12 00 00 non-monetary gold, other unwrought forms (read); 7108 13 and 7112 91 not held
Official guidanceAmount not confirmed
- Customs Tariff (Establishment) (EU Exit) Regulations 2020 (S.I. 2020/1430), as shown on the tariff
Import VAT on investment gold
Exempt Bars/wafers 995+ of a weight accepted by the bullion markets; qualifying coins
Official guidanceAmount not confirmed
- VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21 s.8.1; UK tariff additional code VATE
Import VAT on non-investment gold
20% (standard rate; tariff code 03020) Doré, grain, scrap, bars below 995, non-qualifying coins
Official guidanceAmount not confirmed
- VAT Notice 701/21, s10.7
VAT exemption for supplies of investment gold (with option to tax)
Exempt Supplies of investment gold (incl. rights to it, unallocated gold, loans, swaps, forwards and futures; not options) and agents' services for them; not between an LBMA member and a taxable non-member (standard-rated, SAS)
Official guidanceAmount not confirmed
- VAT Act 1994 Sch 9 Group 15; VAT (Investment Gold) Order 1999
Special accounting scheme (reverse charge) for gold
20%, accounted for by the buyer Standard-rated B2B supplies between VAT-registered (or liable) persons: fine gold, gold grain, gold coins (not margin-scheme), gold-containing goods priced at no more than a negligible amount above the gold value, investment gold on which the option to tax is exercised or supplied between an LBMA member and a non-member, and treatment/processing services producing such gold (Notice 701/21 s.11.2)
Official guidanceAmount not confirmed
- VAT Act 1994 s.55 (named in VGOLD1700; statute not held)
Zero rate for London Bullion Market and central-bank gold transactions
0% Investment gold (incl. futures and options) between taxable LBMA members (TMO; Notice 701/9 s.3.2.4); gold, rights to or part interests in gold held in the UK between central banks or between a central bank and an LBM member (VATA Sch 8 Group 10; Notice 701/21 s.10.4). Not zero-rated: investment gold between an LBMA member and a taxable non-member (standard-rated, special accounting scheme); a futures contract between a member and a non-member that leads to physical delivery (Notice 701/9 s.3.3.2).
Official guidanceAmount not confirmed
- VAT (Terminal Markets) Order 1973 art. 2(2), (4) and arts 4-7; VATA 1994 s.50, Sch 8 Group 10
HMRC MLR registration and annual supervision fee
Not read
Official guidance

Controls

The UK tariff attaches to 7108 12 00 00 a "Restriction on entry into free circulation for Belarus" (from 30 Sep 2023; legal base SI 2023/616) and a "Restriction on export for Belarus" (legal base SI 2022/748): allowed with document code 9011 (DBT licence, GBSAN reference) or 9022 (not subject to / e…
Official guidance
- Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 as amended
A trader accepting or making a cash payment of GBP 10,000 or more for goods (single or linked) is a high value dealer: must register with HMRC first and apply CDD. Threshold changed from EUR 10,000 to GBP 10,000 with effect from 30 Jun 2026.
GBP 10,000 cash (EUR 10,000 before 30 Jun 2026)
Primary lawAmount not confirmed
- MLR 2017 as amended by SI 2026/621, regs 14, 27(3); SI 2026/621 reg 9
Regulated firms apply CDD on a business relationship, a transfer of funds over GBP 800, an occasional transaction of GBP 12,000+ (HVDs: cash GBP 10,000+), suspicion or doubt; EDD for PEPs, non-face-to-face and FATF call-for-action countries (reg 33 as amended 30 Jun 2026); keep records 5 years; nomi…
Occasional transactions GBP 12,000 (general); GBP 10,000 cash (HVD); transfer of funds GBP 800 (from 30 Jun 2026; previously 15,000 / 10,000 / 1,000 euros)
Primary lawAmount not confirmed
- MLR 2017, reg 27
The import into the United Kingdom of gold originating from Russia is prohibited where it was exported from Russia on or after the relevant day. The ban goes by origin, so it applies whichever country the gold is shipped from.
Primary law
- The Russia (Sanctions) (EU Exit) (Amendment) (No. 14) Regulations 2022, inserting reg 46Z11 into SI 2019/855, reg 46Z11(1)
  “The import of gold originating from Russia is prohibited, where that gold has been exported from Russia on or after the relevant day.”
No Great Britain statute imposing CAHRA/OECD due diligence on gold importers was found. Responsible-sourcing duties in London come from the LBMA (RGG mandatory for Good Delivery refiners since 2012; annual audit; Incident Review Process) and the GBI country-of-origin reporting (monthly, mandatory fr…
Standard
- LBMA Responsible Gold Guidance / Good Delivery Rules
UK persons may not provide financial services for foreign exchange reserve and asset management to the Central Bank of Russia, the National Wealth Fund or the Russian Ministry of Finance (or persons owned, controlled or acting for them); the reserves include bullion such as gold - "it is prohibited …
Official guidance
- Russia (Sanctions) (EU Exit) Regulations 2019, reg 18A (as named in the statutory guidance)
Only Good Delivery bars settle loco London: 350-430 fine troy oz, minimum 995.0 fineness, marks = refiner stamp, assay mark, fineness, serial number (max 11 digits or characters), month and year of manufacture (MMYY, since Jan 2019); no laser engraving. Vault managers have complete discretion and an…
Standard
- LBMA Good Delivery Rules 2026; LPMCL account agreements, GD Rules 2.1.5, 2.1.7, 2.4
The Hallmarking Act 1973 regulates describing articles as gold; Schedule 1 Part II exempts "Any raw material (including any bar, plate, sheet, foil, rod, wire, strip or tube) or bullion" (para 7) and coins that are or were current coin of the UK or any other territory (para 3). Bullion bars and lega…
Primary law
- Hallmarking Act 1973
Dealers in exempt investment gold must identify customers (one List 1 and one List 2 document), issue invoices with prescribed details, keep records at least 6 years and notify HMRC within 28 days when an exempt supply first exceeds GBP 5,000 or supplies to one customer exceed GBP 10,000 in 12 month…
GBP 5,000 per supply / GBP 10,000 per customer per 12 months
Primary lawAmount not confirmed
- VAT Regulations 1995; VAT tertiary legislation, reg 31A
LBMA suspended six Russian refiners (Krastsvetmet, Novosibirsk, Uralelectromed, Moscow Special Alloys, Prioksky, Shyolkovsky) from the Good Delivery List on 7 Mar 2022; their bars made from that date are not Good Delivery; stocks already in loco London/Swiss before then remain Good Delivery.
Standard
- LBMA Good Delivery List
Import of gold originating in Russia that was exported from Russia on or after 21 Jul 2022 is prohibited (reg 46Z11); so are acquiring gold that originated in and is located in Russia with the intention that it enter the UK (46Z12), supplying or delivering gold that originated in Russia on or after …
none
Primary law
- Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850, regs 46Z11-46Z16; Sch 3G
Import of relevant processed gold - gold processed (altered, transformed or otherwise operated on) in a third country that incorporates gold which on or after 21 Jul 2022 originated in and was exported from Russia - is prohibited (46Z16C), as is import of gold jewellery (Sch 3G Part 3) originating i…
Primary law
- SI 2022/1110 (Chapter 4JA), regs 46Z16B, 46Z16C, 46Z16D-46Z16I
All smuggled gold may be liable to forfeiture under the Customs and Excise Management Act 1979, even in the hands of an innocent buyer; HMRC advises buyers to check where the gold came from, whether it was declared at import with import VAT paid, and warning signs (below-market price, quick settleme…
Official guidance
- Customs and Excise Management Act 1979; VAT Notice 701/21 s.14

Leg 4: Australia

Back in the origin country: the proceeds of the export

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Price the sale against the LBMA Gold Price (commonly in AUD) or a forward/hedge contract
Who
Mining tenement holder (mining lease) operating a gold mine and mill
Issues
LBMA Gold Price PM (AUD) reference
Industry practice
Commercial pricing practice not documented; the LBMA PM fix is the statutory WA royalty reference.
35
Transfer metal from the miner's metal account to the buyer, or deliver bars, against payment
Who
Australian gold refiner (LBMA Good Delivery-listed)
Issues
Payment for gold sold
Industry practice

Crossings between countries

Australia → Hong Kong SAR China Researched
Papers that cross: AUSTRAC enrolment; AML/CTF program; Outturn / assay statement; Metal account statement; Commercial invoice (GST-free / input-taxed treatment stated); Export declaration and export entry advice (authority to deal, with export entry advice number); Certificate of origin (on request); Air waybill
Hong Kong SAR China → United Kingdom Not researched
Papers that cross: Inbound air waybill; Hong Kong import declaration (Cap. 60E, lodged electronically within 14 days); CBNI advance electronic declaration (CDS) for cash moved as cargo; PBOC Gold and Gold Products Import/Export Permit (中国人民银行黄金及黄金制品进出口准许证); Hong Kong exporter's commercial invoice; Packing list; Outbound air waybill / cross-boundary transport document; Hong Kong export / re-export declaration (Cap. 60E, lodged within 14 days)