Russian Federation [Raw-material export with Minfin inexpediency conclusion] → Australia (refine) → Hong Kong (China SAR) · Sale on HKGX or OTC, with payment and AML duties

Where the goods start

Doré bar - unstamped → Concentrate / black sand

• Exchange-rate-linked export duty on gold

  0% (average USD/RUB below 80), 4% (80-85), 4.5% (85-90), 5.5% (90-95), 7% (95 and above) of the customs value

  Primary lawAmount not confirmed

  • Government Decree 1538 of 21.09.2023, para 1; Decree 532 of 25.04.2024, para 1

• Export duty on gold-bearing concentrates

  Same exchange-rate-linked bands (0-7%) as Decree 1538 para 1 - group 26 (except 2609 00 000 0) is in the list, which covers precious-metal ores and concentrates (HS 2616) Precious-metal ores and concentrates (HS 2616) exported outside the EAEU

  Primary lawAmount not confirmed

  • Government Decree 1538 of 21.09.2023, para 1, para 1

• Mineral extraction tax (NDPI) on gold

  6.0% (art. 342(2)(5): "концентратов и других полупродуктов, содержащих в себе один или несколько драгоценных металлов"), times the rent coefficient KRENTA = 1 for these minerals (art. 342⁸(3)(2)) and the territory coefficient Ktd (art. 342(2²)) Gold-bearing semi-products at the end of the extraction operations (dore/ligature gold, placer and native gold, concentrates)

  Primary lawAmount not confirmed

  • Tax Code Part Two, ch. 26, arts. 337(2)(13), 340(5), 342(2)(5), 342⁸(3)(2)

• NDPI surcharge on gold (2024)

  RUB 78,000 per kg of gold contained in the extracted semi-product (КДРМ = VДРМ x 78 000) Tax periods beginning 1 June - 31 December 2024; gold in semi-products under art. 337(2)(13) extracted on licensed plots

  Primary lawAmount not confirmed

  • Federal Law 96-FZ of 22.04.2024, art. 1(7), adding Tax Code art. 343(21), art. 343(21) (2024 wording)

• NDPI surcharge on gold from 2025

  КДРМ = 0.1 x (ЦЗ / 1000 - 61 000) x VДРМ x Р: 10% of the excess of the month's average world gold price in USD per kg (ЦЗ is USD per tonne, art. 342¹⁰(1)) over USD 61,000 per kg, times the kg of gold contained, times the month's average USD/RUB rate

  Primary lawAmount not confirmed

  • Tax Code art. 343(21) as restated by Federal Law 176-FZ of 12.07.2024, art. 343(21)

• FPP state control of every import from and export to non-EAEU states of goods in tables 1 and 3 of section 2.10 (41-FZ art. 26²; Decree 1137 para 19(b)): the whole batch is presented (for ores and concentrates, HS 2616, the documents only) and controlled within 5 working days; checks of the batch a…

  Primary law

  • EEC Board Decision 30, Annex 14, Annex 2 (Rules) paras 3, 4, 7, 8, 10; Presidential Decree 1137 paras 19, 19¹, Rules paras 3, 10

• From 1 May 2026 export from Russia of refined gold in bars with a total weight over 100 g by individuals, legal entities and entrepreneurs is prohibited, except (a) to EAEU member states through the international airports Moscow (Vnukovo), Moscow (Domodedovo), Moscow (Sheremetyevo) and Vladivostok (…

  Total weight over 100 g

  Primary lawAmount not confirmed

  • Presidential Decree 193 of 25.03.2026; Government Decree 450 of 23.04.2026, para 2, para 4

• Purchase and sale of precious metals (and jewellery and scrap) of RUB 1,000,000 or more is subject to mandatory control and reported to Rosfinmonitoring by the seller within 3 working days; individuals buying jewellery up to RUB 60,000 (RUB 400,000 with a personalised e-payment means) are not identi…

  RUB 1,000,000

  Primary lawAmount not confirmed

  • Law 115-FZ, art. 6(1)(4) sixth paragraph; art. 7(1.4-2)

• Only listed refiners, Goznak and credit organisations may sell refined (investment) bars to individuals, and retailers only bars received on commission or agency from them; buy-back dealers and pawnshops may pass bars bought from individuals only to refiners. Deals between individuals in precious me…

  Primary law

  • Government Decree 604 of 15.05.2024 (Rules paras 3-4, 8); 41-FZ art. 22(6), Rules para 4

• No gold-specific cash-payment limit was found. The RUB 1,000,000 mandatory-control threshold applies whatever the means of payment.

  Unverified

• Export to non-EAEU states of goods in tables 1 and 2 of section 2.10 of the EAEU Single List (table 1 includes refined gold in bars, plates, powder and granules, unique and non-refinable nuggets, other unwrought gold incl. dore, scrap, ores and concentrates) requires a licence issued by Minpromtorg …

  Primary law

  • Presidential Decree 1137 (Regulation paras 4, 22, 23); EEC Board Decision 30, Annex 14 para 5; Minfin Order 10n, paras 4, 22, 23

• Residents must receive export proceeds on their accounts in authorised banks (173-FZ art. 19(1)(1)). Under art. 19(8) this does not apply to contracts priced or payable in foreign currency, except for goods listed there; the list includes HS 7101-7103 and 7112 but not 7108 (gold). Where art. 19 appl…

  Primary law

  • Federal Law 173-FZ art. 19; Presidential Decrees 79 (para 2) and 430, art. 19(1), (8)

• Traceability: participants must record precious-metal operations in GIIS DMDK, with UINs and electronic accompanying documents between participants; refiners report receipt and shipment of metal in any form.

  Primary law

  • 41-FZ art. 12², art. 20(2); Government Decree 270 of 26.02.2021, art. 12²

• Refined metal in standard form must, before it enters circulation, be offered by a purchase proposal to the State Fund institution under Minfin and to the authority of the mining region (where a regional fund exists) - for the next year by 31 December, with an additional proposal within 10 working d…

  Primary law

  • Federal Law 41-FZ, art. 2(5), art. 20(4)-(5)

• LBMA suspended six Russian refiners on 7 Mar 2022; their bars produced from that date are not Good Delivery; Russian bars already in loco London/Swiss before then remain Good Delivery, with clearing banks attesting conformity.

  Standard

• Mined and produced precious metals (except nuggets) must, after the necessary processing, go for refining to organisations on the Government list (41-FZ art. 20(1)); only listed organisations may refine (art. 4(4)); the refining agreement's mandatory terms and the refiner's reporting duties are set …

  Primary law

  • Federal Law 41-FZ, art. 20(1)

• Switzerland: purchase, import, transit and transport into and through Switzerland of gold under Annex 26 (includes HS 7108) originating in Russia and exported from Russia after 4 August 2022 are prohibited (Art. 14d(1)); the same applies to such gold processed in a third country (Art. 14d(2)) and, s…

  Primary law

  • Swiss Ukraine Ordinance SR 946.231.176.72 (Stand 21.09.2026), Art. 14d

• EU: it is prohibited to purchase, import or transfer, directly or indirectly, gold listed in Annex XXVI (HS 7108; 7112 91 gold waste and scrap; ex 7118 90 gold coins) that originates in Russia and was exported from Russia into the Union or to any third country after 22 July 2022 (art. 3o(1)); the sa…

  Primary law

  • Regulation (EU) 833/2014 as amended by 2022/1269, art. 3o

• Japan: import of precious metals originating in Russia and shipped from Russia on or after 1 August 2022 requires the Minister of Finance's permission under FEFTA art. 19(2) (MOF Notice No 443 of 2006 as amended 25 July 2022, item 4); the government announced it on 5 July 2022 as an import ban.

  Primary law

  • MOF Notice No 443 of 2006 as amended 25 Jul 2022, item 4

• UK: import of gold originating in Russia and exported from Russia on or after 21 July 2022 is prohibited (reg 46Z11, Chapter 4J inserted by SI 2022/850, in force 21 Jul 2022), with prohibitions on acquisition with intent to import, supply and delivery, technical assistance, financial services and br…

  Primary law

  • Russia (Sanctions) (EU Exit) Regulations 2019, regs 46Z11-46Z16, 46Z16A-46Z16C

• US: import of gold of Russian Federation origin is prohibited from 28 Jun 2022, except gold located outside Russia before that date (OFAC determination under E.O. 14068 s. 1(a)(i)(A), amended version of 22 Dec 2023). U.S. persons may not deal with the Central Bank, the National Wealth Fund or the Mi…

  Primary law

  • E.O. 14068 and the OFAC determination; E.O. 14024 as amended by E.O. 14114, E.O. 14068 s. 1(a)(i)(A); E.O. 14024 s. 11

    “the importation into the United States of … products of Russian Federation origin”

• Temporary ban from 1 June to 30 November 2026 on export from Russia of precious-metal waste and scrap (HS 7112) and electrical and electronic waste used mainly to recover precious metals (8549 21 000 0, 8549 29 000 0), with exceptions for samples of up to 500 g per batch exported by listed refiners …

  Primary law

  • Government Decree 558 of 16.05.2026, para 1

• Legal entities, entrepreneurs and artist-jewellers operating with precious metals must be on the FPP special register kept in GIIS DMDK; those that should be registered and are not may not carry out operations (41-FZ art. 13¹(2)). Registration within 30 calendar days of state registration (Rules pa…

  Primary law

  • 41-FZ art. 13¹; Government Decree 1052 (Rules paras 2, 5), art. 13¹

• Precious metals and products from them are transported by air, sea, inland water, rail or specialised equipped road vehicles under armed escort; raw materials with less than 1% gold (or 5% silver), jewellery, investment metals (within a weight limit set by the Government) and some other items may mo…

  Primary law

  • Federal Law 41-FZ, art. 29(3)

On the way

Concentrate / black sand → 999.9 kilobar

• GST - first supply of precious metal after refining

  GST-free (0%, input credits allowed) First supply of precious metal after its refining by, or on behalf of, the supplier, where the refiner is a "refiner of precious metal" and the recipient a "dealer in precious metal" (each: an entity that satisfies the Commissioner of the activity - s.195-1)

  Primary lawAmount not confirmed

  • A New Tax System (Goods and Services Tax) Act 1999, s.38-385; s.195-1

• GST on importation of precious metal

  Non-taxable importation (precious metal); otherwise GST 10% of the value of the taxable importation (customs value plus international transport and insurance, s.13-20) Imported gold that meets the precious-metal definition is a non-taxable importation because its supply would be input taxed or GST-free (s.13-10(b)); dore and other gold outside the definition is a taxable importation

  Primary lawAmount not confirmed

  • A New Tax System (Goods and Services Tax) Act 1999, ss.13-5, 13-10(b), 13-20

• GST - other supplies of precious metal

  Input taxed (no GST charged; no input tax credits) Gold (in an investment form) of at least 99.5% fineness (s.195-1 precious metal); "investment form" is not defined in the Act - the ATO describes it as a coin, wafer, bar or other tradeable form with an internationally accepted hallmark (LBMA-approved for gold)

  Primary law

  • A New Tax System (Goods and Services Tax) Act 1999, s.40-100; s.195-1

• GST reverse charge on supplies of goods containing valuable metal

  10% of the price, payable by the recipient A taxable supply of goods consisting wholly or partly of valuable metal (gold, silver, platinum) to a recipient registered or required to be registered, where the market value of the goods does not exceed the valuable metal threshold (i.e. is not at least 10% above the value of the metal in them) or the parties agree in writing - e.g. scrap, dore and other non-investment gold

  Primary lawAmount not confirmed

  • A New Tax System (Goods and Services Tax) Act 1999, Division 86 (ss.86-5, 86-10, 86-25); s.195-1 valuable metal

• Customs duty on gold

  Free HS 7108.11.00, 7108.12.00, 7108.13.00, 7108.20.00 and 7112.91.00 (general rate Free; the rate footnote: FTA originating goods Free unless otherwise shown)

  Official guidanceAmount not confirmed

  • Customs Tariff Act 1995, Schedule 3

• 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

Where the goods arrive

• 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”

• 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

Back in the origin country: the proceeds of the export