Zimbabwe [state buyer/exporter (FGR) or gold dealing licensee] → Japan (refine) → United Arab Emirates · Reconcile assays and pay the balance

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

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Zimbabwe (Doré bar - unstamped → Pre-refined 995 bar (e.g. 'Dubai 995')) ⟶ Japan (Pre-refined 995 bar (e.g. 'Dubai 995') → 999.9 kilobar) ⟶ United Arab Emirates (999.9 kilobar)

Not researched: Zimbabwe → Japan, Japan → United Arab Emirates

Leg 1: Zimbabwe

Where the goods start

Doré bar - unstamped → Pre-refined 995 bar (e.g. 'Dubai 995')

1
Register as an exporter in CEPECS through the authorised dealer
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
CEPECS exporter registration
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.1
2
Obtain the Gold Export Certificate for the lot
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Gold Export Certificate
Official guidance
[unconfirmed] Issuer and form of the 'Gold Export Certificate' are stated in no text held (FX Guidelines, Gold Trade Act and Regulations, Exchange Control Regulations and General Order all read); requested (zw.gap-gec).
3
Prepare assays and a pro-forma invoice showing the quantity, price and total value of the gold
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
FGR bar list for the export lot
Issues
Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30
4
Submit the export application on the RBZ Document Management System with the Gold Export Certificate, Gold Dealership Licence, assays and pro-forma invoice
Who
Authorised dealer bank
Needs
Gold Export Certificate; Gold dealing licence ('Gold Dealership Licence'); Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); CEPECS exporter registration
Primary law
- Exchange Control Regulations SI 109/1996; RBZ Foreign Exchange Guidelines FXD5/2026, Regulations s.20(1)(e) (no export of gold unless authorised by an exchange control authority); Guidelines para 3.2.30 ('All exports of Gold require prior Reserve Bank approval')
5
Approve the gold export within 24 working hours and issue an approval reference number
Who
Reserve Bank of Zimbabwe
Issues
RBZ gold export approval (approval reference number on the Document Management System)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.30
6
Raise the CEPECS Form CD1 quoting the RBZ approval reference
Who
Authorised dealer bank
Needs
RBZ gold export approval (approval reference number on the Document Management System)
Issues
CEPECS Form CD1 (exchange control export form)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.5, 3.2.30
7
Issue the commercial invoice to the foreign buyer/refiner (attached to the export entry)
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Commercial invoice
Official guidance
ZIMRA lists 'Suppliers' invoices' for the export entry; the pro-forma invoice goes to the RBZ (3.2.30). [blocked] ZIMRA page via WebFetch only.
8
Lodge the export bill of entry (Form 21) through a registered clearing agent in ASYCUDA World before the gold leaves, with the CEPECS Form CD1, the invoice and the RBZ approval; pay the clearance fee - 'No duties are payable on export'
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
CEPECS Form CD1 (exchange control export form); RBZ gold export approval (approval reference number on the Document Management System); Commercial invoice
Issues
Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Primary law
[blocked] The ZIMRA clearance page was read only through WebFetch. [unconfirmed] Any gold-specific customs examination is not described.
- Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.54(1), s.61; Regulations s.62(1)(a); Exchange Control Regulations s.21
9
Where the buyer or the importing country's customs requires one (e.g. the UAE import declaration, ae.st-18), obtain a certificate of origin from the Zimbabwe National Chamber of Commerce on its form: the exporter declares 'that all the goods are of ZIMBABWE ORIGIN' and the chamber certifies it; the form carries the invoice, consignee and destination, transport, tariff number, description, net weight and the bill of entry number
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Needs
Commercial invoice; Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Issues
ZNCC certificate of origin for the gold consignment
Secondary
ZNCC's own form read in full (a chamber, not a regulator). [unconfirmed] Whether FGR or other gold exporters obtain one in practice, its fee and turnaround were not found (requested from ZNCC). [inferred] Treated as optional: no Zimbabwean export rule requires it. [blocked] ZIMRA origin page via WebFetch only.
- Customs and Excise Act [Chapter 23:02]; Customs and Excise (General) Regulations 2001, Act s.89(1)(a) ('wholly grown or produced' test for unmanufactured goods); Regulations s.25 (certificates of origin for lower duty - imports)
10
An officer authorises loading by stamping the consignment note or air waybill; the airline accepts the sealed consignment as valuable cargo under the air waybill and the gold must leave Zimbabwe within ten days of the authority
Who
Secure logistics provider / airline
Needs
Customs export bill of entry (Form 21, lodged in ASYCUDA World)
Issues
Air waybill
Primary law
[inferred] Air freight from Harare is assumed; no Zimbabwe source names the route or carriers.
- Customs and Excise (General) Regulations 2001; Customs and Excise Act, Regulations s.63(1), (3); Act s.55(1)

Taxes and fees

Export duty and customs clearance fee
none on export ('No duties are payable on export'); clearance fee per Form 21
Official guidanceAmount not confirmed
- Customs and Excise (General) Regulations 2001, s.62(1)(a)(ii); s.175 (clearance fee)
Gold dealing licence fee
US$200,000 per year
Primary lawAmount not confirmed
- Gold Trade (Licence Fees) Notice 1978, Schedule 2, as replaced by SI 32 of 2023
Presumptive tax on small-scale miners
0% of the purchase price of precious metals Precious metals bought from small-scale miners
Primary lawAmount not confirmed
- Finance Act [Chapter 23:04] s.22C(1)(b) as substituted by Finance Act 2024 s.6, s.22C(1)(b)
Gold royalty, artisanal and small-scale miners
2% (reported, 2025-2026); previously 1% Gold sold by artisanal and small-scale miners
SecondaryAmount not confirmed
- Mines and Minerals Act s.244-245; Finance Act [Chapter 23:04] Schedule to Chapter VII; Income Tax Act 37th Schedule, MMA ss.244-245; 37th Schedule paras 2-3, 7
Gold royalty, 'gold produced by other miners' (price-banded, from 1 January 2026)
3% (sold 'at a time when its price is US$1 200 per ounce'); 5% (above US$1,200 but below US$5,000 per ounce); 10% (above US$5,000 per ounce) 'Gold produced by other miners' (the Schedule item replaced by the Finance Act 2025; the item for small-scale miners is separate and not held)
Primary lawAmount not confirmed
- Finance Act 2025 s.61 (Schedule to Chapter VII of the Finance Act [Chapter 23:04]); Income Tax Act 37th Schedule, s.61; 37th Schedule paras 2, 3, 7
Gold royalty, large-scale producers (before Finance Act 2025)
3% below US$1,200/oz; 5% above US$1,200/oz
SecondaryAmount not confirmed
Implicit cost: 10% ZiG payment to small-scale miners and FGR discount to spot
~5% below spot (best FGR tier) plus 10% of value paid in ZiG (ASM) / 30% (LSM)
SecondaryAmount not confirmed

Controls

Exporters surrender 30% of gross proceeds to the RBZ at the interbank rate and retain 70% indefinitely (retention cut from 75% to 70% in the February 2025 MPS); 50% surrender on overdue proceeds; proceeds due within 90 days.
30% of gross export receipts
Official guidanceAmount not confirmed
- Exchange Control Regulations SI 109/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 35(1)(c); Guidelines paras 3.2.2, 3.2.3; Directive FXD5/2026 para 2
Gold Trade Act licensees and permit holders are 'precious metals dealers' (MLPC Act s.13): identify and verify customers who pay 'in currency equal to or exceeding fifteen thousand United States dollars' (s.15(2)(d)) and whenever ML/TF is suspected, and the beneficial owner (s.15(3)); EDD for PEPs (…
US$15,000 CDD threshold for occasional transactions
Primary lawAmount not confirmed
- MLPC Act [9:24]; FIU DPMS Guidance (2026), MLPC Act ss.13, 15(2)(d), 15(3), 20, 24, 30, 31; Guidance paras 155, 172
Authorised gold bars are FGR-produced 99.5% bars of gazetted weights and dimensions bearing the FGR hallmark; defacing, altering, counterfeiting or smelting them is an offence (level 14 fine or up to 15 years).
Primary law
- Gold Trade Act [Chapter 21:03] as amended by Finance Act 2025, ss.2, 3, 12A
A traveller may take out at most 'US$2,000 or its equivalent in any other currency, combination of currencies or gold coins' in foreign cash, and ZiG cash equivalent to US$2,000 (FX Guidelines 3.2.33-3.2.34). Personal-use gold articles in baggage are exempt from the export prohibition (Exchange Cont…
US$2,000
Official guidanceAmount not confirmed
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), paras 3.2.33-3.2.34
All gold won must be delivered 'not later than the 10th of every month' to the holder of a gold dealing licence (GTA s.6(1)), who 'shall deal with such gold in accordance with directions issued to him by the Minister responsible for finance' (s.6(3)). Only licence or permit holders, location holders…
All gold, any quantity
Primary law
- Gold Trade Act [Chapter 21:03], ss.3(1), 4, 5, 6(1), 6(3)
Gold Trade Enforcement Unit (FGR staff plus police) may inspect mining locations and premises, examine documents and devices, and seize gold; obstruction is an offence.
Primary law
- Gold Trade Act [Chapter 21:03] Part IIIA, ss.22B-22E
Payment for gold delivered to refineries: ASGM not more than 90% foreign currency / not less than 10% ZiG; LSGM 70% / 30% (from 1 March 2026).
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.29
'No person shall dispatch by post any postal article containing gold unless he is authorized to do so by any regulation' (GTA s.10(1)); authorised: licence holders, permit holders, location holders or tributors and their employees or agents (GT Regulations reg 8); suspect articles may be detained an…
Primary law
- Gold Trade Act [Chapter 21:03]; Gold Trade Regulations 1978, s.10; reg 8
No person may export gold unless authorised by an exchange control authority (Exchange Control Regulations s.20(1)(e)); 'All exports of Gold require prior Reserve Bank approval', applied for by the authorised dealer on the Document Management System with 'The Gold Export Certificate', 'Gold Dealersh…
Primary law
- Exchange Control Regulations SI 109/1996; Exchange Control Act; RBZ FX Guidelines FXD5/2026, Regulations s.20(1)(e); Act s.5(4c); Guidelines para 3.2.30
  “a fine of three times the value of the item”
'No person shall smelt or change the form of any manufactured article containing gold unless he has received the permission of the Minister' (GTA s.12(1)); fine up to level nine or two years (s.12(2)).
Primary law
- Gold Trade Act [Chapter 21:03], s.12
Contravening s.3(1): without special circumstances 'imprisonment for a period of not less than five years or more than ten years', not suspendable (s.3(3)(a), (4)); with special circumstances up to five years or a fine up to level nine or twice the value of the gold (s.3(3)(b)); the same for ss.4, 5…
Primary law
- Gold Trade Act [Chapter 21:03], ss.3(3)-(4), 24, 30
On 4 March 2024 the US ended the Zimbabwe sanctions programme and designated President Mnangagwa and 10 other individuals plus Sakunda Holdings, Fossil Agro and Fossil Contracting under Global Magnitsky, citing involvement in gold and diamond smuggling networks. FGR is not named. US persons must scr…
Official guidance

Leg 2: Japan

On the way

Pre-refined 995 bar (e.g. 'Dubai 995') → 999.9 kilobar

11
Land the consignment and place it in a bonded area (保税地域) under customs control; the import declaration is made after the goods enter the bonded area
Who
Secure logistics carrier / airline
Needs
Air waybill; Commercial invoice; Packing list
Primary law
- Customs Act, Art. 67-2(1), (3)
12
If the gold is of Russian origin and was shipped from Russia on or after 1 Aug 2022, obtain the Minister of Finance's permit (application to the Director-General of Customs) before import; customs checks origin from the clearance documents and the markings on the packages
Who
Bullion trading company (importer / exporter)
Issues
MOF precious-metals export/import permit
Primary law
- FEFTA Art. 19(2); Foreign Exchange Order Art. 8; MOF Notice No. 443 of 2006, item 4, Notice item 4
13
File the written import declaration (goods, quantity, value, origin, consignor); serial-numbered bars go under statistical code 7108.12-010 with the invoice or packing list listing the serial numbers (from 1 Apr 2026); duty rate is free
Who
Bullion trading company (importer / exporter)
Needs
Commercial invoice; Invoice / packing list showing the bar serial numbers (customs requirement from 2026); Commercial invoice; Air waybill; Bar list (serials, weights, fineness)
Issues
Import declaration / permit (commercial)
Primary law
- Customs Act; Customs Act Enforcement Order, Customs Act Art. 67; Order Art. 59(1)
14
Examine the consignment (X-ray, detection equipment, physical inspection) before permitting import
Who
Japan Customs
Official guidance
- Customs Act, Art. 67 (goods must undergo necessary inspection)
15
Pay import consumption tax of 10% (7.8% national + local consumption tax of 22/78 of it = 2.2%) on the customs value plus any duty before the goods leave the bonded area
Who
Bullion trading company (importer / exporter)
Needs
Import declaration / permit (commercial)
Issues
Import consumption tax receipt
Primary law
- Consumption Tax Act; Local Tax Act, CTA Arts. 4(2), 5(2), 28(4), 29(i); Local Tax Act Art. 72-83
16
Grant the import permit; goods released to the importer
Who
Japan Customs
Needs
Import declaration / permit (commercial); Import consumption tax receipt
Issues
Import declaration / permit (commercial)
Primary law
- Customs Act, Art. 67
17
Onboard the supplier: KYC and supply-chain due diligence under LBMA RGG (and APTCP verification where the refiner is buying as a dealer)
Who
Refinery (LBMA Good Delivery / OSE-designated brand)
Issues
Refiner supplier KYC pack; APTCP verification record
Standard
- LBMA Responsible Gold Guidance; APTCP, APTCP Art. 4
18
Receive, weigh, sample and assay the incoming material
Who
Refinery (LBMA Good Delivery / OSE-designated brand)
Needs
Import declaration / permit (commercial)
Issues
Receipt weighing and assay record
Industry practice
Refinery intake practice not documented in a Japanese source read.
19
Refine and cast 1 kg bars of at least 99.99% fineness stamped with the refiner's trademark, fineness and serial
Who
Refinery (LBMA Good Delivery / OSE-designated brand)
Needs
Receipt weighing and assay record
Issues
Refiner bar certificate; Bar list; Invoice / packing list showing the bar serial numbers (customs requirement from 2026)
Form
Doré bar - unstamped → 999.9 kilobar
Official guidance
20
Settle with the customer on the final assay (metal account credit or purchase, with qualified invoice and consumption tax)
Who
Refinery (LBMA Good Delivery / OSE-designated brand)
Needs
Receipt weighing and assay record
Issues
Refining settlement / final invoice; Qualified invoice
Industry practice
No Japanese refining agreement read.
21
Publish the annual LBMA RGG assurance report
Who
Refinery (LBMA Good Delivery / OSE-designated brand)
Issues
LBMA RGG annual assurance report
Standard
22
Deposit deliverable bars (OSE-designated brand, 1,000 g, 99.99%+) in an OSE-designated warehouse (rule: commercial warehouses in Tokyo or Kanagawa; list as at 27 Jul 2020: 7 companies, 9 warehouses, all in Tokyo)
Who
Bullion trading company (importer / exporter)
Needs
Refiner bar certificate; Import declaration / permit (commercial)
Official guidance
- OSE delivery procedures, Ⅲ 1-2; Appendices 7-8
23
Issue a warehouse receipt (倉荷証券) per delivery unit and brand stating product, pieces, brand, quantity, purity, serial numbers, fire insurance, storage fee paid to the delivery period, and theft/loss insurance
Who
OSE-designated warehouse
Issues
OSE warehouse receipt
Official guidance
- OSE delivery procedures, Ⅲ 1(2)
24
File the written export declaration (HS 7108; serial-numbered bars under export code 7108.12-100 with the invoice or packing list listing the serial numbers, from 1 Aug 2026) and obtain the export permit
Who
Bullion trading company (importer / exporter)
Needs
Bar list; Invoice / packing list showing the bar serial numbers (customs requirement from 2026)
Issues
Commercial invoice; Export declaration / permit
Primary law
- Customs Act; Customs Act Enforcement Order, Customs Act Art. 67; Order Art. 58
25
If the destination is Russia (or North Korea), obtain the Minister of Finance's permit for the precious-metal export, applying to the Director-General of Customs at least about a week ahead
Who
Bullion trading company (importer / exporter)
Issues
MOF precious-metals export/import permit
Primary law
- FEFTA Art. 19(2); Foreign Exchange Order Art. 8; MOF Notice No. 443 of 2006, items 1 and 3, Notice items 1, 3
26
If bars are hand-carried and exceed 1 kg (90%+ purity), file the FEFTA carrying declaration
Who
Bullion trading company (importer / exporter)
Issues
FEFTA carrying declaration (export)
Primary law
- FEFTA; Foreign Exchange Order; MOF Ordinance on Foreign Exchange, FEFTA Art. 19(3); FE Order Art. 8-2; FX Ordinance Art. 10
27
Inspect and release for export; carrier takes custody and issues the air waybill
Who
Japan Customs
Needs
Export declaration / permit
Issues
Air waybill (outbound)
Primary law
28
Keep the export permit as proof for the consumption-tax export exemption (0%)
Who
Bullion trading company (importer / exporter)
Needs
Export declaration / permit
Primary law
- Consumption Tax Act, Art. 7(1)(i), 7(2)

Taxes and fees

Consumption tax on domestic sales of gold
10% Sales of bars and scrap inside Japan, including dealer buy-back from the public
Primary lawAmount not confirmed
- Consumption Tax Act; Local Tax Act, CTA Arts. 4(1), 5(1), 29(i); Local Tax Act Art. 72-83
Export exemption (zero rate)
0% Gold exported from Japan with export permit as proof
Primary lawAmount not confirmed
- Consumption Tax Act, Art. 7(1)(i), 7(2)
High-value asset rule for gold purchases
n/a (restricts small-business exemption and simplified taxation) A business buying or importing gold/platinum bullion, gold/platinum coins or gold/platinum products priced by weight for 2 million yen or more (tax-exclusive) in a taxable period: no small-business exemption and no simplified taxation from the next period for about three years
Primary law
- Consumption Tax Act; CTA Order; CTA Regulations, CTA Arts. 12-4(3), 37(3)(v); Order Art. 25-5(4); Regulations Art. 11-3
Import consumption tax (national 7.8% + local 2.2%)
10% All gold imports, cargo or carried, any state
Primary lawAmount not confirmed
- Consumption Tax Act; Local Tax Act, CTA Arts. 4(2), 5(2), 28(4), 29(i); Local Tax Act Art. 72-83
Customs duty on gold (HS 7108)
Free: basic rate 無税 and WTO rate (無税); every EPA column 無税 (temporary, GSP and LDC columns blank) Gold powder, unwrought, semi-manufactured and monetary gold
Official guidanceAmount not confirmed
- Customs Tariff Act and applied tariff schedule (2026-04-01), heading 71.08

Controls

Precious-metals dealers are specified business operators: verification at the time of transaction for sale contracts over 2 million yen, whatever the means of payment; verification records kept 7 years; transaction records (7 years) for sales over 2 million yen paid in cash; suspicious transaction r…
Sale contract price over 2 million yen (verification); over 2 million yen and paid in cash (transaction record)
Primary lawAmount not confirmed
- APTCP Arts. 2(2)(xliii), 4, 6, 7, 8; Enforcement Order Arts. 7(1)(vi), 15(1)(iii)(c); Regulations Art. 22(iv)
Customs emergency reinforcement from 28 Nov 2024 after a 2024 resurgence: detection equipment, more thorough passenger and cargo inspection, stricter penalty handling.
Official guidance
Further measures announced at the special meeting of 27 Nov 2025: intelligence-led import inspection with high-performance equipment; physical checks of exports against fictitious exports and handling of gold of unknown provenance; confiscation by notice disposition for unpermitted imports (the firs…
Official guidance
No input tax credit for purchases the buyer knew were smuggled (1 Apr 2019) or bought tax-free by tourists (1 Apr 2024); gold/platinum bullion purchases need the seller's ID copy (1 Oct 2019). This removes the dealer's tax benefit from buying smuggled gold.
Primary law
- Consumption Tax Act Art. 30(11)-(12); CTA Order Art. 50(2); CTA Regulations Art. 15-7
OSE deliverable gold: 1,000 g bars of 99.99% minimum, smooth surface, stamped with an exchange-designated trade name or trademark and the fineness, held in an OSE-designated warehouse (Tokyo). Brands are admitted only if LBMA-accredited, with 5 years of operation, average output of 5 t a year and 2 …
Official guidance
- OSE Gold Standard Futures specification and delivery procedures
Any gold carried into Japan must be declared on the passenger declaration (question on gold bullion or products). Gold bullion of 90%+ gold content over 1 kg in total carried on the person, inbound or outbound, needs the written Declaration of Carrying of Means of Payment etc. (customs declaration a…
Any quantity (passenger declaration); over 1 kg of gold bullion with 90%+ gold content, carried (written declaration)
Primary lawAmount not confirmed
- FEFTA Art. 19(3); FE Order Art. 8-2(1)(ii); FX Ordinance Art. 10; Customs Act Art. 67; Customs Act Order Arts. 58-59
Buyer of gold bullion files a payment record with the tax office naming the seller (with My Number), which makes buy-back sales traceable.
Consideration over 2 million yen (ITA Order Art. 350-7)
Primary lawAmount not confirmed
- Income Tax Act Arts. 224-6, 225(1)(xiv); ITA Order Art. 350-7
Import of precious metals of Russian origin (gold bullion, gold alloy bullion, non-circulating gold coins and other articles mainly of gold) shipped from Russia on or after 1 Aug 2022 needs the Minister of Finance's permission, applied for at customs; introduced and administered as an import ban. Tr…
Primary law
- FEFTA Art. 19(2); Foreign Exchange Order Art. 8; MOF Notice No. 443 of 2006 item 4 (amended 25 Jul 2022), Notice item 4
Export of precious metals to Russia needs the Minister of Finance's permission (from 5 Apr 2022), as does any precious-metal export to North Korea or import of North-Korean-origin or -shipped precious metals; travellers' personal effects excepted. MOF guidance defines gold bullion for this purpose a…
Primary law
- FEFTA Art. 19(2); Foreign Exchange Order Art. 8; MOF Notice No. 443 of 2006 items 1 and 3, Notice items 1, 3
Serial-numbered gold (bars stamped with refiner mark, serial number, fineness and weight) is declared under its own statistical code (import 7108.12-010 from 1 Apr 2026; export 7108.12-100 from 1 Aug 2026) and the invoice or packing list listing the serial numbers is submitted; customs may check the…
Official guidance
- Customs notices of March and July 2026
Unpermitted import or export, or a false declaration: up to 5 years' imprisonment (拘禁刑) and/or a fine of up to 10 million yen, or up to five times the goods' value where that exceeds 10 million yen (Customs Act Art. 111(1)); before April 2018 the Customs Act fine cap was 5 million yen (MOF, No…
Primary law
- Customs Act Arts. 110, 111; Consumption Tax Act Art. 64; FEFTA Art. 71
Until 31 Oct 2026: gold and platinum bullion cannot be sold tax-free to visitors, being excluded from tax-free goods as "not for ordinary daily use" (CTA Order Art. 18(2)(i)). Replaced from 1 Nov 2026 by jp.ctl-tax-free-shop-2026.
Primary law
- CTA Art. 8; CTA Order Art. 18(2)(i)
From 1 Nov 2026 tax-free sales to visitors become a refund system (the shop is exempt only once customs confirms export within 90 days and it holds the customs confirmation), and gold and platinum bullion and gold and platinum coins are named as goods excluded from tax-free sale. Supersedes jp.ctl-t…
Primary law
- CTA Art. 8(1)-(5) as amended by Act No. 13 of 2025; CTA Regulations Art. 6 (from 1 Nov 2026), CTA Art. 8; Regulations Art. 6

Leg 3: United Arab Emirates

Where the goods arrive

29
Pre-contract KYC on the Nigerian exporter: corporate docs, UBO, MBC/export-permit evidence, mine-of-origin declaration
Who
DMCC importer / trader
Needs
Bank-to-bank reference confirmation (not a public letter) on the Nigerian exporter
Issues
Importer's KYC/due-diligence pack on the Nigerian exporter; Evidence pack from the Nigerian exporter: export licence/permit, mine location, legal existence of the ASM operation
Official guidance
[conflict] For an ordinary DMCC trader the binding CDD duties are those of CR 134/2025 (Arts. 5-14); DMCC RBD-GPM binds only its Accredited Members (see ae.div-dmcc-role). [inferred] "Highest-scrutiny category" for ASM is the model's reading of Rule 1.6, not a phrase in the Rules.
- DMCC RBD-GPM Rules v2/2020; Cabinet Resolution 134/2025, DMCC Rules 1.4-1.8 (KYC; Rule 1.6 specific requirements for ASM supply), Rules 2.4-2.8 (red flags); CR 134 Art. 25(1) (records at least 5 years)
30
File the Dubai Customs declaration on Mirsal 2 with invoice, packing list, certificate of origin and air waybill (for a free-zone consignee the Customer Guide's 'FZ Transit In' type appears to apply, not import to local); disclose the precious metals crossing the border
Who
DMCC importer / trader
Needs
Air waybill; Certificate of origin; Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority); Commercial invoice; Packing list
Issues
Dubai Customs declaration filed online (for goods entering a free zone: "FZ Transit In"); Disclosure of precious metals crossing the UAE border (cargo included)
Official guidance
No UAE import permit for gold: Dubai Customs lists DMCC as restricting authority only for "Pearls, Diamonds, Rough Diamonds etc." (Customer Guide App. I). FZ Transit In (s.15.12.2): "foreign goods originated from any country may be brought into the free zones without being subject to customs duties or taxes. The owner of the goods in the Documents shall be a Free Zone Licensee"; documents MAWB/HAWB, commercial invoice, certificate of origin, packing list, delivery order. Mainland duty: the GCC exempted list's gold line is printed "71060000" (silver's heading) [summary][blocked]. Cross-border disclosure: see ae.doc-pm-disclosure-ae. [unconfirmed] Neither Dubai Customs guide names the declaration type for gold into a DMCC company or the DMCC Vault. [conflict] Supporting documents are due within 14 days (Customer Guide s.15.7) or 30 days (Service Guide v9 App. A) - see ae.div-customs-doc-deadline. KPMG (secondary): periodic "Goods Consumption within FZ" declaration under Dubai Customs Notice 17/2020.
- Dubai Customs Customer Guide v3.03; Dubai Customs Service Guide v9; Federal Decree-Law 10/2025, Customer Guide s.15.12.2 (FZ Transit In), App. J (DMCC declarations at the Customer Service Center at DMCC); FDL 10/2025 Art. 10 (cross-border disclosure)
31
Import VAT: registered importer accounts for VAT on its own return (reverse charge); investment-grade gold is zero-rated, doré is not
Who
DMCC importer / trader
Issues
Import VAT accounted on the importer's own VAT return (registered importer)
Primary law
Investment precious metals = gold, silver or platinum of 99% purity or more, in a form tradeable in global bullion markets (ER Art. 36(2), not amended in the consolidation to CD 100/2025); their supply or import is zero-rated (Art. 45(8)). [inferred] Doré below 99% does not qualify. [unconfirmed] DMCC's absence from the Designated Zones was checked only against the 2017 list (secondary copy). [not-read] FDL 16/2025 amendments (from 1 Jan 2026) not held.
- Federal Decree-Law 8/2017 on VAT; Executive Regulation (Cabinet Decision 52/2017, as amended; consolidated to CD 100/2025), Law Art. 45(8), 48(1), 49; ER Art. 36(2), 48(1), 48(5), 50(1)
32
If the importer sells the doré to the refiner (rather than toll-refining it): refiner gives two written statements before supply; importer issues a tax invoice without VAT (reverse charge)
Who
DMCC importer / trader
Issues
Refiner's two written statements: VAT-registered, and buying to resell or use in production; Tax invoice without VAT for the importer-to-refiner sale
Primary law
[inferred] Conditional: the model reads the reverse charge as not applying where the refiner only toll-refines metal the importer keeps title to; the sources read do not address toll refining.
- Cabinet Decision 127/2024; VAT Executive Regulation, CD 127 Art. 2(1), 2(3) (two written declarations before supply; supplier keeps them and verifies registration), 2(4) (no declarations: no reverse charge); ER Art. 59(1)(l)
33
Deposit refined bars into DMCC Vault (operated by Brink's)
Who
DMCC Vault (operated by Brink's)
Needs
Manufacturer certificate accompanying UAEGD bars (states year of manufacture if not stamped)
Issues
DMCC Vault deposit/withdrawal receipt; DMCC Tradeflow warrant (optional; used for pledging and title transfer)
Official guidance
DMCC: the Vault is "Owned by DMCC and operated by Brink's Global Services" and "DMCC can assist with all customs processes". [not-read] Deposit/withdrawal documents and any bonded status of the Vault are not published; the receipt document is inferred.
34
Reconcile the provisional (origin) assay against the Dubai refiner's outturn assay: within the contract's splitting limit the two assays are commonly averaged; beyond it an umpire assay decides (the assay closer to the umpire's is used, and the party further from it pays the umpire); settle the difference and pay the final balance
Who
DMCC importer / trader
Needs
Refiner outturn/assay report; Commercial invoice
Issues
Final invoice from the Nigerian exporter (against Dubai outturn assay); Reconciliation of provisional vs outturn assay; Balance/final payment wire; DPMSR filed in goAML for the final settlement
Secondary
[unconfirmed] Debit and credit notes are not described in the two contracts read; the Johnson Matthey contract settles by metal credit, adjusted after the umpire result.
- Refining/sale contract settlement clause -- splitting limit + umpire assay if the two figures diverge beyond it

Taxes and fees

Customs duty on gold imports
0% for goods entering a free zone (FZ Transit In); mainland imports of gold: 0% under the GCC exempted-commodities list (read via WebFetch only) Unwrought and semi-manufactured gold
Official guidanceAmount not confirmed
- Dubai Customs Customer Guide v3.03; GCC common customs law; UAE list of exempted commodities, Customer Guide s.9 (duty suspended for goods admitted into free zones), s.15.12.2
Domestic reverse charge on precious metals and precious stones between registered businesses
Recipient accounts for VAT Supplies of gold, silver, platinum, palladium, precious stones and jewellery made of them, for resale or production, between VAT-registered persons, with the buyer's written declaration (CD 127/2024, replacing CD 25/2018)
Primary law
- Cabinet Decision 127/2024; FTA VATP043, Art. 1 (Goods: precious metals - gold, silver, palladium, platinum - precious stones and jewellery mostly of them), Art. 2(1)-(4), Art. 4 (repeals CD 25/2018)
  “Precious Metals, Precious Stones and jewelry made of any Precious Metals or Precious Stones”
Special reverse charge on gold and diamonds between registrants (Cabinet Decision 25/2018)
Registered recipient accounts for VAT Gold and products mostly of gold not qualifying for zero-rating, and diamonds, supplied between registrants; exports of gold items and investment precious metals outside its scope (VATP029)
Official guidance
- Cabinet Decision No. 25 of 2018
Import VAT
5% standard; 0% for investment precious metals (99%+ purity, tradeable form) Doré is not investment gold, so it is standard-rated; refined bars of 99%+ are zero-rated
Primary lawAmount not confirmed
- Federal Decree-Law 8/2017 on VAT; Executive Regulation, Art. 3 (5%), 45(8), 48(1), 49; Exec. Reg. Art. 36(2), 48, 50(1)
  “a standard rate of 5% Tax shall be imposed on any supply or Import”

Controls

Precious metals crossing the UAE border must be disclosed; declarations are also required for precious metals over AED 60,000 crossing through cargo, mail or shipments, cargo being declared through the official customs systems.
AED 60,000
Primary lawAmount not confirmed
- Federal Decree-Law 10/2025; CBUAE Regulation on the Declaration of Currencies, BNIs, and Precious Metals and Stones (OG 703, 31 May 2021), FDL 10/2025 Art. 10 (duty to disclose, per the disclosure system issued by the ICP with the Central Bank), Art. 41(3) (regulations under FDL 20/2018 remain effective insofar as not conflicting), Art. 34 (penalty)
  “Any person entering into or departing from the State shall be under the obligation to make a disclosure whenever they carry currencies, bearer negotiable instruments, precious metals, or valuable stones, in accordance with the disclosure system issued by the Federal Authority for Identity, Citizenship, Customs and Port Security, in coordination with the Central Bank”
Dealers in precious metals and stones are DNFBPs for any single cash transaction, or linked transactions, of AED 55,000 or more (CR 134/2025 Art. 3 item 3), and keep records for at least 5 years (Art. 25). The DPMSR report, including for dealings with companies of AED 55,000 or more paid in cash or …
AED 55,000
Primary law
- Cabinet Resolution 134/2025; MoET Supplemental Guidance for DPMS 2026, CR 134 Art. 3(3), Art. 25(1); Guidance s.1.4.1
  “when carrying out any single cash transaction or several transactions that appear to be linked and whose value equals or exceeds fifty-five thousand dirhams (AED 55,000)”
Supply-chain entities and precious-metals dealers must have due-diligence management systems, identify and assess supply-chain risks and adopt a risk-management strategy (Decree Art. 1(A)); refiners must also appoint an independent third-party auditor and submit a due-diligence report (Art. 1(B)), u…
Primary law
- Ministerial Decree 68/2024; MoE Due Diligence Regulations v1 (2022), Decree Art. 1(A), 1(B), Art. 3 (penalties under the AML law)

Leg 4: Zimbabwe

Back in the origin country: the proceeds of the export

35
Receive payment within three months (90 days) from export or when contractually due
Who
Gold exporter (FGR or other gold dealing licence holder with RBZ approval)
Issues
Receipt of export proceeds
Primary law
- Exchange Control Regulations SI 109/1996; Exchange Control (General) Order SI 110/1996; RBZ FX Guidelines FXD5/2026, Regulations ss.5, 21; General Order s.13(2) ('within three months from the date of export'); Guidelines para 3.2.2
36
Pre-acquit the Form CD1 within 48 hours of receiving the proceeds
Who
Authorised dealer bank
Issues
CD1 acquittal (proceeds received)
Official guidance
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026), para 3.2.7
37
Sell 30% of gross proceeds to the RBZ at the weighted-average willing-buyer willing-seller interbank rate; the exporter keeps 70% indefinitely (50% surrender where proceeds were overdue)
Who
Authorised dealer bank
Issues
Sale of 30% surrender portion to RBZ at the WBWS interbank rate
Official guidance
[unconfirmed] Whether the general 30% surrender applies to FGR's own gold export proceeds is not stated. The February 2026 MPS (para 233) keeps 70% retention for all sectors 'with the exception of small-scale gold producers, whose retention shall be 90%'.
- RBZ Foreign Exchange Guidelines FXD5/2026 (version 2.0, March 2026); FXD5/2026, FXG para 3.2.3; FXD5 para 2.2

Crossings between countries

Zimbabwe → Japan Not researched
Papers that cross: CEPECS exporter registration; Gold Export Certificate; Assays supporting the RBZ export application; Pro-forma invoice: quantity, price and total value of gold to be exported (FXG 3.2.30); RBZ gold export approval (approval reference number on the Document Management System); CEPECS Form CD1 (exchange control export form); Customs export bill of entry (Form 21, lodged in ASYCUDA World); ZNCC certificate of origin for the gold consignment; Air waybill
Japan → United Arab Emirates Not researched
Papers that cross: MOF precious-metals export/import permit; Import declaration / permit (commercial); Receipt weighing and assay record; Refiner bar certificate; Bar list; Invoice / packing list showing the bar serial numbers (customs requirement from 2026); Commercial invoice; Export declaration / permit; Air waybill (outbound)

Paperwork gaps

jp.st-01 expects Packing list; the earlier legs don't model this paper
jp.st-02 expects Bar list (serials, weights, fineness); the earlier legs don't model this paper
ae.st-18 expects Packing list; the earlier legs don't model this paper