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

Where the goods start

Doré bar - unstamped → 999.9 kilobar

• 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

• 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

On the way

• Consumption tax on gold jewellery

  5% Gold jewellery at retail

  Primary lawAmount not confirmed

  • Consumption Tax Regulations; Caishui [1994] 95, Rate table item 4.1; Caishui [1994] 95 points 1-4, 7

• Export of gold-containing goods: VAT-exempt without refund

  VAT-exempt (no export refund; input VAT not refunded) Goods containing gold or platinum listed in annex 8, incl. HS 71081100, 71081200, 71081300 and 71082000; diamonds and diamond jewellery

  Primary law

  • MOF/SAT Announcement 2026 No. 11, Art. 6(1)1(4)

• No export VAT rebate on gold

  No rebate on gold; for gold jewellery only the processing value added is rebated

  Primary law

  • Caishui [2002] 142 point 3, replaced by Guoshuifa [2005] 125, Point 3

• Import customs duty on unwrought gold (HS 7108)

  Unverified

• Import-stage VAT on gold and gold ore

  Exempt Imported gold (incl. standard gold) and gold ore

  Primary lawAmount not confirmed

  • Caishui [2002] 142, Point 1

• VAT on standard gold sold off-exchange

  13% (standard VAT rate on goods) Standard gold not sold through SGE or SHFE

  Primary lawAmount not confirmed

  • MOF/SAT Announcement 2025 No. 11 point 2; VAT Law, 2025 No. 11 point 2; VAT Law art. 10(1)

• Earlier VAT regime for SGE members' sales of standard gold (Caishui [2002] 142 point 2)

  No physical delivery: exempt; physical delivery: the tax authority issued a special invoice at the actual price and VAT was levied and immediately refunded, with urban construction tax and education surcharges exempt (for sales through the exchange with its settlement voucher)

  Primary law

  • Caishui [2002] 142, Point 2

• VAT on standard gold withdrawn by a member for investment use

  VAT levied and immediately refunded to the exchange (即征即退), urban construction tax and education surcharges exempt; the exchange issues the member a special invoice (label 会员单位投资性黄金) whose VAT the member deducts; the member's onward sales carry ordinary invoices only Member withdrawals for direct sale or processing into 99.5%+ bars, ingots or legal gold coins

  Primary law

  • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 points 1(1), 5; SAT No. 23 point 2

• VAT on SGE / SHFE trades of standard gold without physical delivery

  Exempt: the seller's sale to the exchange, and the exchange's sale while no physical delivery takes place; the buyer receives a settlement invoice (结算发票) Standard gold (AU99.99/99.95/99.9/99.5; 50 g, 100 g, 1 kg, 3 kg, 12.5 kg) traded on the exchange

  Primary lawAmount not confirmed

  • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1; SAT No. 23 point 1

• VAT on standard gold withdrawn for non-investment use or by a client

  Exempt at the exchange (ordinary invoice); general-taxpayer buyer deducts input VAT at 6%; onward sales taxed normally with special invoices Jewellery, industrial and other non-investment uses; all client withdrawals

  Primary lawAmount not confirmed

  • MOF/SAT Announcement 2025 No. 11; SAT Announcement 2025 No. 23, 2025 No. 11 point 1(2)-(3); SAT No. 23 points 3-4

• VAT on producers' sales of non-standard gold and gold ore

  Exempt Sales of gold other than standard gold, and gold ore (incl. associated gold), by gold producers and dealers

  Primary lawAmount not confirmed

  • Caishui [2002] 142, Point 1

• VAT on gold producers' and dealers' sales of non-standard gold and gold ore (2026-2027)

  Exempt Sales of gold other than standard gold (AU9999, AU9995, AU999, AU995 in 50 g, 100 g, 1 kg, 3 kg, 12.5 kg) and of gold ore (incl. associated gold) by gold producers and dealers

  Primary lawAmount not confirmed

  • MOF/SAT Announcement 2026 No. 10, 二(二)24

• No permit is needed for processing trade, for movements between special customs supervision areas/bonded sites and abroad or between such areas, or for repair, return and temporary import/export; Customs supervises them.

  Primary law

  • Gold and Gold Products Import/Export Measures, Art. 20

• Special preventive measures: for persons on the counter-terrorism list, the Foreign Ministry notices implementing UN Security Council targeted financial sanctions, and the PBoC high-risk list, institutions must immediately stop services and restrict transfers of funds and assets and report to the PB…

  Primary law

  • AML Law 2024; PBoC PM AML Measures; Anti-Foreign Sanctions Law, AML Law art. 40; Measures art. 27; AFSL arts. 11-12

• Mining without a mining right: ordered to stop; confiscation of tools, equipment and the minerals taken; fine of 3 to 5 times the market value of the minerals illegally extracted, or RMB 100,000 to 1,000,000 where nothing was extracted or the value is under RMB 100,000; suspension if the activity co…

  Primary law

  • Mineral Resources Law 2024, Art. 64

• Dealers in precious-metal spot trading are specific non-financial institutions (AML Law art. 64(3)). Under the PBoC Measures (in force 1 Aug 2025) they must run AML controls, assess risk at least every 3 years, carry out CDD incl. beneficial owners on cash of RMB 100,000 or more, report large cash t…

  Cash of RMB 100,000 single or daily cumulative (Measures arts. 2, 15, 24)

  Primary lawAmount not confirmed

  • AML Law 2024; PBoC PM AML Measures; Import/Export Measures, AML Law arts. 34, 64; Measures arts. 2, 13-16, 24-26, 38; Import/Export Measures art. 22

• SGE deposit and delivery accept only standard ingots/bars from SGE-accredited refiners, or from suppliers accredited by an SGE-recognised international market. The Delivery Rules (Annex 2) and the overseas criteria name LBMA Good Delivery refiners; overseas refiners can also be accredited directly (…

  Official guidance

  • SGE Detailed Delivery Rules; SGE Vault Measures; SGE Refiner Measures and Overseas Criteria, Delivery Rules Art. 11 and Annex 2; Vault Measures Art. 4; Overseas Criteria arts. 6, 19

• Exports of unwrought gold are subject to the same PBoC qualification and per-batch permit; the export is VAT-exempt without refund (MOF/SAT 2026 No. 11 art. 6 and annex 8).

  Primary law

  • Gold and Gold Products Import/Export Measures, Arts. 3, 8

• Foreign-exchange receipts and payments arising from gold imports and exports follow SAFE rules (Measures art. 23): current-account payments are unrestricted but need a genuine, lawful transaction basis checked by the bank and are made against valid documents (FX Regulations arts. 5, 12, 14); receipt…

  Primary law

  • Gold and Gold Products Import/Export Measures; FX Regulations, Measures art. 23; FX Regulations arts. 5, 9, 12, 14

• Import and export of gold and gold products in the PBoC catalogue need a PBoC permit presented to Customs: one permit per batch, used within 40 working days, only for entities holding the PBoC qualification; the PBoC may restrict quantities for macro-economic reasons (art. 3). No other channel is la…

  Every batch

  Primary law

  • Gold and Gold Products Import/Export Measures; Customs Law, Measures arts. 3, 4, 8, 17, 21; Customs Law art. 24

• Gold carried into China by travellers is not limited in quantity but must be declared to Customs; gold may be carried out only against a PBoC certificate or up to the quantity declared on entry (Gold and Silver Regulations arts. 25-26). The Import/Export Measures (art. 4) leave rules for individuals…

  Primary law

  • Gold and Silver Regulations (rev. 2011); Import/Export Measures, Regulations arts. 25-26; Measures art. 4

• Qualified importers/exporters must help balance domestic physical supply; imported gold must be registered and first traded on the State Council-approved gold spot exchange (SGE).

  Primary law

  • Gold and Gold Products Import/Export Measures, Art. 6

• Import and export of national gold reserves are handled only by the PBoC; gold coins (incl. commemorative) only by an institution the PBoC designates (Measures art. 5). Gold coins are minted and issued only by the PBoC (Gold and Silver Regulations art. 21).

  Primary law

  • Gold and Gold Products Import/Export Measures, Art. 5

Where the goods arrive

• 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

• 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

Back in the origin country: the proceeds of the export