Brazil [merchandise gold (concession holder)] → South Africa (refine) → United Kingdom · Loco London OTC sale and settlement

Where the goods start

Doré bar - unstamped → Doré bar - stamped/exporter-sealed

• CFEM (Compensação Financeira pela Exploração de Recursos Minerais) on gold

  1.5% Gold ore, doré, garimpo gold

  Primary lawAmount not confirmed

  • Lei 8.001/1990 as amended by Lei 13.540/2017, art. 2, 2-A, Anexo

• Export duty (Imposto de Exportação) on gold

  None on gold as financial asset (only IOF applies, CF art. 153 §5); on gold as merchandise, only if CAMEX lists it (not confirmed)

  Primary lawAmount not confirmed

  • CF art. 153 §5; Decreto 6.759/2009, Decreto 6.759 arts 212 §2, 215

• Income tax on gains from gold operations

  Capital gains on gold financial-asset operations, taxed as financial-market income

  Primary law

  • Lei 7.766/1989, art. 13

• IOF-ouro (tax on gold as financial asset)

  1% Gold as financial asset or exchange instrument, on first acquisition only; the sole tax on such gold

  Primary lawAmount not confirmed

  • Lei 7.766/1989; Decreto 6.306/2007; Lei 11.196/2005; CF art. 153 §5, Lei 7.766 arts 4, 8-10; Decreto 6.306 arts 36-40; Lei 11.196 art. 70 II a

• IOF on the FX operation bringing in export receipts

  0% Export proceeds converted into reais

  Primary lawAmount not confirmed

  • Decreto 6.306/2007, art. 15-B I

• No repatriation or surrender requirement: exporters may keep foreign-currency export proceeds abroad (Lei 11.371 art. 1); receipts may arrive before or after shipment, including by credit to an account abroad of the authorised institution (Res. BCB 277 art. 46).

  Primary law

  • Lei 11.371/2006 art. 1, as reworded by Lei 14.286/2021 art. 26

• PLGs only for Brazilian citizens or garimpeiro cooperatives (Lei 7.805 art. 5); research authorisations and mining concessions only for Brazilians, companies under Brazilian law with head office and administration in Brazil, or cooperatives (CF art. 176 §1; Decreto 9.406 arts 16, 30).

  Primary law

  • Lei 7.805/1989; CF art. 176 §1, Lei 7.805 art. 5

• Extracting Union minerals without a title is a crime: usurpation, 1-5 years, with the same penalty for whoever acquires, transports, holds or sells the product (Lei 8.176 art. 2 §1); mining without authorisation also carries 6 months-1 year (Lei 9.605 art. 55) and seizure of the product (Lei 7.805 …

  Primary law

  • Lei 8.176/1991; Lei 9.605/1998; Lei 7.805/1989, Lei 8.176 art. 2; Lei 9.605 art. 55; Lei 7.805 art. 21

    “Art. 2° Constitui crime contra o patrimônio, na modalidade de usurpacão, produzir bens ou explorar matéria-prima pertencentes à União, sem autorização legal ou em desacordo com as obrigações impostas pelo título autorizativo. Pena: detenção, de um a cinco anos e multa. § 1° Incorre na mesma pena aquele que, sem autorização legal, adquirir, transportar, industrializar, tiver consigo, consumir ou comercializar produtos ou matéria-prima, obtidos na forma prevista no caput deste artigo.”

• Persons buying and selling gold as financial asset (Lei 9.613 art. 9 II) and dealers in precious metals (art. 9 parágrafo único XI) must identify clients, keep records (at least 5 years), register with their regulator or COAF and report to COAF (arts 10-11); BCB-authorised institutions follow Circ…

  Primary law

  • Lei 9.613/1998; Circular BCB 3.978/2020, Lei 9.613 arts 9-11

• No ban on paying for gold in cash was found in the law in force. BCB-authorised institutions record cash operations above R$2,000 with the bearer's CPF (Circular 3.978 art. 33) and report to COAF, by the next business day, cash deposits, withdrawals and payments of R$50,000 or more (art. 49). PL 3.0…

  R$2,000 (record); R$50,000 (COAF report)

  Primary lawAmount not confirmed

  • Circular BCB 3.978/2020, arts 33, 49

• Every exit and entry of gold as financial asset is made by the BCB or an authorised institution, with a PF-authorised domestic transporter, under an e-DMOV; exit always gets a scheduled physical verification (IN RFB 1.082 art. 11 §2); gold with irregular fiscal documents is seized (art. 21 III).

  Primary law

  • IN RFB 1.082/2010, arts 1, 11 §2, 19, 21

    “§ 2º O controle referido no caput será processado com base na Declaração Eletrônica de Movimentação Física Internacional de Valores (e-DMOV).”

• Gold as financial asset may be bought at first acquisition only by BCB-authorised institutions (Lei 7.766 art. 1; IN RFB 2.138 art. 3 I), whose acquisition invoice proves the purchase (Lei 12.844 art. 39 II); regularly constituted garimpeiro cooperatives may buy at origin and must resell to the BCB …

  Primary law

  • Lei 7.766/1989; Lei 12.844/2013; Lei 11.685/2008, Lei 7.766 arts 1-2; Lei 12.844 art. 39 II; Lei 11.685 art. 9

• All gold financial-asset operations and their transport must be covered by fiscal documents; irregular gold is seized by the Receita Federal (Lei 7.766 art. 3; Decreto 6.306 arts 46, 56). Since 1 Aug 2023 the document is the NF-e Ouro Ativo Financeiro; an invoice with inaccurate data is inidônea (I…

  Primary law

  • Lei 7.766/1989; IN RFB 2.138/2023, Lei 7.766 art. 3; IN arts 1 §1, 3, 6

• Before its first acquisition, garimpo gold may be transported only within the gold-producing region (the geological province of the same gold mineralisation where the workings are) up to an authorised buyer.

  Primary law

  • Lei 12.844/2013, art. 38 §§2, 5

• The presumption of legality of the gold and of the buyer's good faith once the seller's documents were filed (Lei 12.844 art. 39 §4) was suspended by the STF in ADI 7.345 (interim order quoted in the EMI of PL 3.025/2023, which also ordered the Executive to adopt within 90 days a new framework for …

  Primary law

  • STF ADI 7.345 and 7.273; IN BCB 406/2023, IN BCB 406 art. 2

• Mining in Indigenous lands requires Congress authorisation (CF art. 231 §3), the garimpeiro-cooperative priority of art. 174 §§3-4 does not apply there (art. 231 §7), and a PLG does not apply to Indigenous lands (Lei 7.805 art. 23 a). Gold from garimpo in Indigenous lands cannot be lawfully prod…

  Primary law

  • Constituição Federal; Lei 7.805/1989, CF art. 231 §§3, 7; Lei 7.805 art. 23 a

    “§ 7º Não se aplica às terras indígenas o disposto no art. 174, § 3º e § 4º”

On the way

Doré bar - stamped/exporter-sealed → LBMA Good Delivery 400oz bar

• VAT on other domestic supplies of gold

  15% Domestic gold supplies not zero-rated (e.g. recycled gold to banks; sales to traders)

  Primary lawAmount not confirmed

  • Value-Added Tax Act 1991

• VAT zero-rating of gold supplied to the SARB, SA Mint and banks

  0% Refined primary gold sold to the SARB, the SA Mint or a registered bank; recycled gold excluded (Lueven Metals, ZACC 23 June 2026)

  Primary lawAmount not confirmed

  • Value-Added Tax Act 1991, s.11(1)(f)

• SADPMR licence and permit fees

  Refining licence R20,000; beneficiation licence R5,000; jeweller's permit R500; import permit R1,000; certificate R1,000; special permit R5,000; appeal R500 (Annexure A, 2014) Applications and renewals

  Primary lawAmount not confirmed

  • Precious Metals Regulations, Annexure A as substituted by GN R737 (GG 38014, 22 Sept 2014)

• A business dealing in high-value goods (items valued in that business at R100,000 or more) is an accountable institution for transactions in which it receives payment of R100,000 or more (Schedule 1 item 20, from 19 Dec 2022): FIC registration (s.43B), risk management and compliance programme (s.42)…

  Payment of R100,000 or more in a transaction; goods valued at R100,000 or more

  Primary lawAmount not confirmed

  • FICA 38 of 2001, Schedule 1 item 20; ss.20A-21H, 22-23, 28, 29, 42, 43B

• A UN Security Council Chapter VII resolution identifying persons or entities 'has immediate effect for the purposes of this Act upon its adoption' (FICA s.26A(1)); the FIC Director must give notice of it (s.26A(3)). No person may, directly or indirectly, acquire, collect, use, possess or own propert…

  Primary law

  • FICA 38 of 2001, ss.26A-26C

    “A resolution adopted by the Security Council of the United Nations when acting under Chapter VII of the Charter of the United Nations, providing for financial sanctions which entail the identification of persons or entities against whom member states of the United Nations must take the actions specified in the resolution, has immediate effect for the purposes of this Act upon its adoption by the Security Council of the United Nations.”

• Contravening s.5(4) (as enacted; replaced by s.5A from 7 June 2013), 19, 20(2) or 28 is an offence with a fine up to R100 000 or up to two years' imprisonment, or both (s.99(1)(a)); failing to notify the Minister before beneficiating abroad (s.26(3)) carries up to R500 000 for each day (s.99(1)(f)).

  Primary law

  • MPRDA 2002, ss.98, 99(1)(a), 99(1)(f)

• Goods exported for sale must be sold, and the full proceeds received, not later than six months from shipment; an Authorised Dealer may allow credit of up to 12 months. Proceeds must be offered for sale to an Authorised Dealer within 30 days or dealt with under the CFC rules. The Authorised Dealer r…

  Official guidance

  • Exchange Control Regulations; Currency and Exchanges Manual, Regs 6, 10, 11; B.18(B), (D)

• No export of unwrought or semi-fabricated gold except with the approval of the National Treasury under the Exchange Control Regulations, granted with the Minister's concurrence (PMA s.12(1)); no gold may be exported without Treasury permission (Reg 3); applications to export gold in any form are ref…

  Primary law

  • Precious Metals Act; Exchange Control Regulations, PMA s.12(1); Reg 3

• Producers submit gold specimens (nuggets, concentrate, dore) to the SAPS Forensic Science Laboratory every six months, and importers submit specimens of imported metal, building a forensic database to trace seized gold to its source.

  Primary law

  • Precious Metals Act; Precious Metals Regulations, s.22(1); reg 29

    “Any producer or any person who imports precious metal must submit to the Forensic Science Laboratory of the South African Police Service such specimens of any precious metals produced or imported by him or her as may be prescribed.”

• Except with Treasury permission, only authorised dealers may buy, borrow, sell or lend gold other than wrought gold (Reg 2). A resident entitled to sell gold must offer it for sale to the Treasury within 30 days unless exempted (Reg 5). Producers exempted by FinSurv from Reg 5 may sell their total o…

  Primary law

  • Exchange Control Regulations 1961, Regs 2, 5, 22

• No import of unwrought or semi-fabricated precious metal without an SADPMR import permit (valid up to one year), issued after consulting the National Commissioner and the National Treasury, on documentary proof of origin (s.10(2)); the Regulator or SAPS may inspect and sample imported metal (s.10(3)…

  Primary law

  • Precious Metals Act, s.10, s.22(1)

    “must state the origin of the precious metal in question, the purpose of the import”

• Export approval requires projections of monthly production against sales showing the applicant contributes to local demand; approval only where provision has been made to meet local demand for beneficiation.

  Primary law

  • Precious Metals Regulations; Precious Metals Act, reg 23(3)(a) as substituted by GN R387

• Minted gold bars must be 10, 50 or 100 g, of prescribed dimensions and at least 999.9 fine (reg 28, Annexure B Table 1); only approved manufacturers may make them and no more than 500 000 troy ounces a year may be manufactured (reg 27B).

  Primary law

  • Precious Metals Regulations, regs 27B, 28; Annexure B

    “The quantity of minted bars that maybe manufactured in the Republic may not exceed 500 000 troy ounces in a calendar year”

• Only a refining-licence holder, an authorised dealer, a producer (for gold it won or recovered), an SADPMR certificate holder, a holder of a special permit (metal not exceeding a prescribed mass, for scientific or beneficiation purposes or jewellery) or a beneficiation-licence holder may acquire, po…

  Primary law

  • Precious Metals Act, s.4(1), s.20(1)

• Rand Refinery, as an LBMA Good Delivery refiner, applies KYC and conflict-free sourcing policies to depositors and publishes responsible-gold and LBMA compliance reports.

  Industry practice

  • LBMA Responsible Gold Guidance

• Unwrought or semi-fabricated gold may not be carried outside a mine or refinery boundary without the prescribed waybill.

  Primary law

  • Precious Metals Act; Precious Metals Regulations, s.13; reg 26

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