Brazil [financial-asset gold (BCB-authorised institution)] → Canada (refine) → United Kingdom · Loco London OTC sale and settlement
以研究形式发布的公开法律与官方指引,不构成法律、税务或金融建议。
研究内容本身以英文撰写。标题和标签已翻译,调查结果和引文未翻译。
向研究提问
逐段路线
研究记录的每个步骤、税费和管制,附法律依据及研究的可靠程度。
巴西 (Doré bar - unstamped) ⟶ 加拿大 (Doré bar - unstamped → LBMA Good Delivery 400oz bar) ⟶ 英国 (LBMA Good Delivery 400oz bar)
第 1 段:巴西
货物起点
- 1
Send the gold from the PCO to head office or the refinery with an NF-e Ouro remittance note, by secure carrier
- 执行方
- BCB-authorised financial institution buying gold (DTVM) and its purchase post (PCO)
- 所需
- NF-e Ouro - first acquisition of gold from a PLG
- 出具
- NF-e Ouro - remittance note (PCO to head office/refinery)
法律原文IN RFB 2.138/2023; Lei 7.766/1989, IN art. 3 V b-c; Lei 7.766 art. 3 §1
- 2
Refine buttons or doré into 999.9 bars and issue a bar list; the refiner covers the return of the gold with an NF-e Ouro (IN RFB 2.138 art. 3 §2).
- 执行方
- Domestic gold refinery
- 所需
- NF-e Ouro - remittance note (PCO to head office/refinery)
- 出具
- Domestic refiner's bar list / certificate
- 形态
- Smelted button/bar → 999.9 kilobar
行业惯例Refining to 999.9 is practice; only the return invoice (IN art. 3 §2) is law.
- 3
Sell gold to another institution or client and issue an NF-e Ouro (negotiation); no further IOF-ouro (it falls only on first acquisition)
- 执行方
- BCB-authorised financial institution buying gold (DTVM) and its purchase post (PCO)
- 出具
- NF-e Ouro - negotiation between institutions
法律原文IN RFB 2.138/2023; Lei 7.766/1989, IN art. 3; Lei 7.766 art. 8
- 4
Contract the export sale and close the FX contract with an FX-authorised institution; the gold as exchange instrument is traded only with authorised institutions, supervised foreign institutions or the BCB; the FX contract is a required attachment of the e-DMOV. Proceeds may be received before or after shipment and may be kept abroad.
- 执行方
- Authorised institution exporting gold as a financial asset / exchange instrument
- 出具
- Contrato de câmbio (FX contract); Commercial invoice
法律原文Lei 14.286/2021; Resolução BCB 277/2022; IN RFB 1.082/2010, Lei 14.286 art. 3; Res. 277 arts 46, 66 §2; IN 1.082 art. 4 II c
- 5
Issue the NF-e Ouro Ativo Financeiro for the export (DAO operation 5), recording the e-DMOV number and the domestic transporters.
- 执行方
- Authorised institution exporting gold as a financial asset / exchange instrument
- 所需
- NF-e Ouro - first acquisition of gold from a PLG
- 出具
- NF-e Ouro - export of gold (financial asset / exchange instrument); Packing list
法律原文IN RFB 2.138/2023, art. 3 III
- 6
Book the shipment with the airline, which issues the air waybill for the valuable cargo (the e-DMOV must attach the international transport document, IN RFB 1.082 art. 4 II a); after boarding, the carrier records the boarding data in the e-DMOV within 2 days (art. 23).
- 执行方
- Valuables carrier (PF-authorised domestic transporter) and international air carrier
- 所需
- Packing list
- 出具
- Air waybill; Consignment Security Declaration
法律原文Acceptance as valuable cargo and the consignment security declaration are industry practice.
IN RFB 1.082/2010, arts 4 II a, 23
- 7
File the e-DMOV de saída with a digital certificate, attaching the international transport document, packing list, FX contract and the sales invoice, with the sealed volumes at the declared verification place; on registration (active CNPJ, PF-authorised domestic transporter, authorised international carrier) the Receita Federal selects a channel and schedules physical verification; clearance follows an RVES or RVFV without blocking discrepancies; gold with irregular fiscal documents is seized.
- 执行方
- Authorised institution exporting gold as a financial asset / exchange instrument
- 所需
- Contrato de câmbio (FX contract); NF-e Ouro - export of gold (financial asset / exchange instrument); Air waybill; Packing list
- 出具
- e-DMOV de saída (gold as financial asset); RVES / RVFV - customs security-element and physical verification reports in the e-DMOV
法律原文[conflict] br.div-edmov-invoice-conflict: IN 1.082 art. 4 II e and the RFB e-DMOV page still name the "Modelo VI" invoice of IN SRF 49/2001, which IN RFB 2.138 revoked (effective 1 Aug 2023); the model takes the NF-e Ouro (export) as the invoice attached.
IN RFB 1.082/2010; Lei 7.766/1989, IN arts 1, 3 §2, 4 II, 9, 10, 11 §2, 19, 21 III; Lei 7.766 art. 3 §2
- 8
Send the pre-shipment notice (weights, fineness, AWB) to the foreign refiner or buyer
- 执行方
- Authorised institution exporting gold as a financial asset / exchange instrument
- 所需
- Air waybill
- 出具
- Pre-shipment notification to refiner/buyer
行业惯例
税费
CFEM (Compensação Financeira pela Exploração de Recursos Minerais) on gold
1.5% Gold ore, doré, garimpo gold
法律原文金额未确认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)
法律原文金额未确认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
法律原文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
法律原文金额未确认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
法律原文金额未确认Decreto 6.306/2007, art. 15-B I
管制
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).
法律原文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).
法律原文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 …
法律原文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…
法律原文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)
法律原文金额未确认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).
法律原文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 …
法律原文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…
法律原文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.
法律原文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 …
法律原文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…
法律原文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”
第 2 段:加拿大
途经
Doré bar - unstamped → LBMA Good Delivery 400oz bar
- 9
Hold a Business Number with RM import-export program account, registered in the CARM Client Portal (and optional RPP financial security)
- 执行方
- Importer of record (doré, scrap or bars for refining)
官方指引 - 10
Present the shipment for release: classify doré as 7108.12.00.22 (bars 7108.12.00.11/.21, scrap 7112.91) - all Free under MFN and every preferential tariff; no import permit; gold goods from Russia or a person in Russia (Schedule 9) and precious-metal scrap from Russia (Schedule 13) are prohibited; goods produced wholly or in part by forced labour are prohibited
- 执行方
- Licensed customs broker
- 所需
- Export customs declaration accepted by the dispatching country's customs; Commercial invoice; Air waybill
- 出具
- Commercial invoice from the foreign shipper
法律原文Forced-labour prohibition: Customs Tariff item 9897.00.00 (ca.src-tariff-ch98). MFN is not available for goods of Belarus, North Korea or Russia (guide-3).
Customs Tariff; SEMA (Russia) Regulations, Tariff item 7108.12.00; SEMA (Russia) ss.3.11, 3.16
- 11
Account for the goods on a Commercial Accounting Declaration (Type C at release, or Type AB within five business days of release under RPP) and pay duties and taxes on the statement of account; imported precious-metal bars are non-taxable for GST, and doré, unwrought gold, scrap and concentrates imported to be refined are non-taxable
- 执行方
- Importer of record (doré, scrap or bars for refining)
- 所需
- Commercial invoice from the foreign shipper
- 出具
- Commercial Accounting Declaration
法律原文Customs Act; Accounting for Imported Goods and Payment of Duties Regulations; Excise Tax Act; Non-Taxable Imported Goods (GST/HST) Regulations, Customs Act s.32; SOR/86-1062 s.10; ETA Sched VII s.8; SOR/91-31 s.3(a), (b)
- 12
Keep import records for 6 years; self-correct within 90 days; CBSA may verify origin, value and classification for 4 years
- 执行方
- Importer of record (doré, scrap or bars for refining)
- 所需
- Commercial Accounting Declaration
官方指引90-day correction duty read in Customs Act s.32.2(2); six-year retention and four-year verification from CBSA guide-7 and D17-1-21 (the regulation fixing the period was not read).
- 13
Onboard the supplier: KYC, OECD five-step risk assessment, sanctions/PEP/adverse-media screening, confirm gold is not imported, purchased or acquired from Russia or a person in Russia
- 执行方
- Private LBMA Good Delivery refiner in Canada
- 所需
- Refining (toll) agreement, mine - Canadian refiner; Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority)
- 出具
- Supplier KYC pack and acknowledgement of the refiner's procurement policy; Onboarding and daily screening record; non-Russian origin confirmation
法律原文[inferred] SEMA element is law; KYC and OECD process are LBMA/refiner practice, not a Canadian statute for refiners.
SEMA (Russia) Regulations s.3.11; LBMA RGG; OECD DDG, s.3.11
- 14
Receive, weigh, melt and sample the lot; assay in the refinery lab and issue the outturn
- 执行方
- Private LBMA Good Delivery refiner in Canada
- 所需
- Supplier KYC pack and acknowledgement of the refiner's procurement policy; Onboarding and daily screening record; non-Russian origin confirmation
- 出具
- Refiner outturn assay and settlement statement
官方指引 - 15
Refine to 999.9 (or 999.99) and cast LBMA Good Delivery 400 oz bars, 100 oz or 1 kg bars bearing the refiner's mark
- 执行方
- Private LBMA Good Delivery refiner in Canada
- 出具
- Bar list of refined bars (GD 400 oz, 100 oz, kilobars)
- 形态
- Doré bar - stamped/exporter-sealed → LBMA Good Delivery 400oz bar
官方指引 - 16
Settle outturn with the supplier: credit fine metal to its metal account or buy the metal, with final invoice
- 执行方
- Private LBMA Good Delivery refiner in Canada
- 所需
- Refiner outturn assay and settlement statement
- 出具
- Refiner's final invoice / metal-account credit against outturn
行业惯例 - 17
First supply of the refined bars by the refiner (or the owner on whose behalf they were refined) is zero-rated for GST/HST; refining fees charged to the metal owner are generally taxable
- 执行方
- Private LBMA Good Delivery refiner in Canada
- 出具
- Invoice for sale of refined bars (zero-rated first supply by the refiner / exempt resale)
法律原文Refining-fee taxability is CRA guidance (17-1 para 35), not a specific statutory provision.
Excise Tax Act, s.123(1) 'precious metal'; Sched VI Part IX s.3
- 18
For any purchase or sale of $10,000 or more as a dealer in precious metals: verify identity, keep records, report cash of $10,000+ (LCTR), virtual currency (LVCTR) and suspicious transactions
- 执行方
- Private LBMA Good Delivery refiner in Canada
- 出具
- Record of $10,000+ purchase or sale and client identification; Large cash transaction report; Suspicious transaction report; Large virtual currency transaction report
法律原文s.65(2) excludes purchases/sales in connection with extracting precious metals from a mine or manufacturing a product; its application to refiners buying doré is not settled in the texts read.
PCMLTF Regulations, ss.65, 66, 126, 148
- 19
Optionally hold refined bars in allocated (segregated, identified bars) or unallocated storage at the Royal Canadian Mint vaults in Ottawa or Winnipeg (institutional clients only), with semi-annual counts
- 执行方
- Royal Canadian Mint (federal Crown corporation: refinery and vault)
- 所需
- Bar list of refined bars (GD 400 oz, 100 oz, kilobars)
- 出具
- Allocated weight list / unallocated account statement
官方指引 - 20
Re-export imported or toll-refined bars: file CERS export declaration (non-US destinations, CAD 2,000+) and hand the proof of report number to the carrier
- 执行方
- Exporter of record (mine, refiner or bullion trader)
- 所需
- Commercial Accounting Declaration
- 出具
- CERS export declaration and proof of report number
法律原文 - 21
Carry the re-exported bars under air waybill
- 执行方
- Secure precious-metals carrier / airline
- 所需
- CERS export declaration and proof of report number
- 出具
- Air waybill
行业惯例
税费
GST on imported precious metal
Non-taxable Imported precious metals under any circumstances (SOR/91-31 s.3(a)); unwrought gold, waste and scrap and gold concentrates imported to be refined into precious metals (s.3(b))
法律原文Excise Tax Act; Non-Taxable Imported Goods (GST/HST) Regulations, ETA Sched VII s.8; SOR/91-31 s.3(a), (b)
GST/HST on 'precious metal' (gold bars, ingots, coins, wafers of 99.5%+)
Zero-rated when supplied by the refiner or the person on whose behalf it was refined (Sched VI Part IX s.3); otherwise exempt as a financial service (Sched V Part VII s.1); supplies by a financial institution to a non-resident zero-rated (Sched VI Part IX s.1) ref.ms-gd400, ref.ms-9999 bars; not doré, granules or jewellery
法律原文金额未确认Excise Tax Act, s.123(1); Sched V Part VII s.1; Sched VI Part IX ss.1, 3
GST/HST on doré and other non-qualifying gold
5% GST (s.165(1)), or HST in participating provinces; exports zero-rated where Sched VI Part V s.1 applies Doré, granules, scrap sold domestically; refining fees charged to metal owners
法律原文金额未确认Excise Tax Act, s.165(1), (2); Sched VI Part V s.1
Customs duty on gold (7108) and gold scrap (7112.91)
Free (MFN and every applicable preferential tariff, incl. UST, CPTPT, UKT) Doré, bullion, powder, semi-manufactures, monetary gold, gold scrap
法律原文金额未确认Customs Tariff, 7108.11-7108.20, 7112.91
管制
S.C. 2026, c. 4 (Bill C-12, royal assent 26 Mar 2026) amended the PCMLTFA and the AMP Regulations: penalty ranges per violation $1 to $40,000 (minor), $1 to $4,000,000 (serious) and $1 to $20,000,000 (very serious) (AMP Regulations s.5, as amended by s.118), subject to the Act's maxima of $4,000,000…
法律原文PCMLTFA and PCMLTF AMP Regulations as amended by S.C. 2026, c. 4, Act ss.9.6(1.1), 73.1; SOR/2007-292 s.5
CBSA officers may enter premises where goods destined for export are reported, loaded or stored and examine them (Customs Act ss.97.01-97.02, added by S.C. 2026, c. 4, Part 1).
法律原文Customs Act, ss.97.01, 97.02
Extractive entities (listed in Canada, or meeting two of $20m assets, $40m revenue, 250 employees) must report and publish payments of $100,000 or more per category per payee to governments in Canada and abroad within 150 days after year end; keep records 7 years; fine up to $250,000 (ESTMA ss.8, 9,…
法律原文Extractive Sector Transparency Measures Act, ss.8, 9, 13, 24
A DPMS receiving $10,000 or more in cash in a single transaction must file a large cash transaction report (unless from a financial entity or public body); amounts received within 24 consecutive hours from or for the same person are aggregated.
$10,000 cash
法律原文金额未确认PCMLTF Regulations, ss.66, 126
No exchange control or export-proceeds repatriation requirement identified.
未经核实Since 2025 the Ontario Minister may suspend MLAS access, prohibit or terminate prospector's licences, deny leases and (with Lieutenant Governor in Council approval) cancel claims or terminate leases for the protection of the strategic national mineral supply chain.
法律原文Ontario Mining Act, ss.4.1(8)-(14), 26.1, 81(1.1), 176.1
No legal cap on cash payments for gold is in force. Bill C-2 (Strong Borders Act, first reading 3 Jun 2025) Part 11 would add PCMLTFA s.77.5 making it an offence for a person or entity engaged in a business to accept a cash payment, donation or deposit of $10,000 or more (single or prescribed relate…
$10,000 (proposed)
法律原文金额未确认Bill C-2 (not enacted), proposed PCMLTFA s.77.5
Travellers must declare currency or monetary instruments of CAN$10,000 or more; gold bullion is not a monetary instrument and moves as goods through customs.
CAN$10,000
法律原文金额未确认Cross-border Currency and Monetary Instruments Reporting Regulations, ss.1, 2
Dealers in precious metals and precious stones are PCMLTFA reporting entities for purchases or sales of $10,000 or more (compliance program, KYC, beneficial ownership, PEPs, records kept at least five years, STR, LCTR, LVCTR, listed-person property and sanctions-evasion reports). Excluded: purchases…
$10,000 per purchase or sale
法律原文金额未确认PCMLTF Regulations, ss.1(2), 65, 148
Export reporting (not licensing): non-monetary gold must be declared through CERS/G7 EDI when worth CAD 2,000+ and going anywhere but the US; exports to the US of non-restricted goods are exempt.
CAD 2,000; US destinations exempt
法律原文金额未确认Customs Act s.95; Reporting of Exported Goods Regulations, REGR ss.3, 6(b), 7
Tariff item 9897.00.00 prohibits importation of "Goods manufactured or produced wholly or in part by prison labour" and "Goods mined, manufactured or produced wholly or in part by forced labour or child labour as those terms are defined in section 2 of the Fighting Against Forced Labour and Child La…
法律原文Customs Tariff, Schedule, tariff item 9897.00.00
Canada hosts three LBMA Good Delivery gold refiners: Royal Canadian Mint (Ottawa, listed ~1919), CCR Refinery - Glencore Canada Corporation (Montreal East, ~1956) and Asahi Refining Canada Limited (Brampton, 15/06/1961). Output is accepted in London; Asahi and the Mint also state COMEX acceptance.
标准Gold is not on the Export Control List: no export permit, licence or state approval is required to export gold, and no state buyer or export monopoly exists.
法律原文Export and Import Permits Act; Export Control List, EIPA s.13; SOR/89-202
Every Ontario patent, lease or other disposition of lands, claims or mining rights is subject to the condition that "all ores or minerals raised or removed therefrom shall be treated and refined in Canada so as to yield refined metal or other product suitable for direct use in the arts without furth…
法律原文Ontario Mining Act, s.91
No person in Canada or Canadian abroad may export, sell, supply or ship unwrought (710812) or semi-manufactured (710813) gold, wherever situated, to Russia or to any person in Russia (Schedule 6 Part 1 items 176-177; also jewellery and other listed articles). Exception: personal effects.
法律原文Special Economic Measures (Russia) Regulations, s.3.08, Schedule 6 Part 1 items 176-177
Persons in Canada and Canadians abroad may not import, purchase or acquire any Schedule 9 good from Russia or from any person in Russia: gold powder (710811), other unwrought (710812), semi-manufactured (710813), monetary gold (710820), jewellery (711319) and goldsmiths' wares (711419) of precious m…
法律原文Special Economic Measures (Russia) Regulations, s.3.11, Schedule 9
No person in Canada or Canadian abroad may import, purchase or acquire Schedule 13 goods, wherever situated, from Russia or a person in Russia; Schedule 13 item 137 is heading 7112 (waste and scrap of precious metal). Added by SOR/2025-143.
法律原文Special Economic Measures (Russia) Regulations, s.3.16, Schedule 13 item 137
Entities producing, selling or distributing goods, or importing goods, that are listed in Canada or meet two of $20m assets, $40m revenue, 250 employees must report to the Minister by May 31 each year on steps taken to prevent forced and child labour in their supply chains (S.C. 2023, c. 9, ss.2, 9,…
法律原文Fighting Against Forced Labour and Child Labour in Supply Chains Act, ss.9, 11
第 3 段:英国
货物终点
- 22
Apply customer due diligence to the foreign seller before buying (identity, beneficial owner, purpose, risk assessment, sanctions/PEP screening)
- 执行方
- Bullion dealer / trader (importer of record, usually an LBMA member)
- 出具
- Supplier KYC pack received by the UK buyer; MLR customer due diligence file
法律原文[unconfirmed] Whether a non-bank wholesale bullion trader paid by wire is within the MLR at all (e.g. as a financial institution under reg 10) - consolidated MLR not held. [not-read] Reg 27 quoted via WebFetch; MLR not held.
Money Laundering Regulations 2017, reg 27
- 23
Establish that the gold is not Russian-origin gold exported from Russia on or after 21 Jul 2022, not relevant processed gold incorporating such gold, and not Russian gold jewellery exported on or after 29 Oct 2022; check where the goods were originally consigned or exported from; if Russian origin is possible, apply to DBT's Import Sanctions Team for a licence or contact it; declare document code 9022 (not subject to / exempt from sanctions) or 9011 (licence) on CDS and keep the evidence to produce on demand
- 执行方
- Bullion dealer / trader (importer of record, usually an LBMA member)
- 所需
- Export customs declaration accepted by the dispatching country's customs
- 出具
- Importer's Russia-sanctions origin evidence file
法律原文[inferred] The guidance and tariff do not list specific evidence documents; the required kinds are this module's inference.
Russia (Sanctions) (EU Exit) Regulations 2019 as amended by SI 2022/850 and SI 2022/1110, regs 46Z11, 46Z16B, 46Z16C
- 24
Fly the bars into the UK as valuable cargo (typically Heathrow) under an air waybill
- 执行方
- Secure valuables carrier
- 出具
- Air waybill, inbound valuables consignment
未经核实UK valuables-cargo handling not researched in this pass.
- 25
Submit a full import declaration on CDS (procedure code, commodity code 7108 12 00 00 for unwrought gold, DUCR, consignor/consignee, value, licences; EORI); declare sanctions document code 9022 or 9011; claim the investment-gold VAT exemption with additional code VATE where the bars are 995+ of a weight accepted by the bullion markets
- 执行方
- Customs agent / declarant using CDS software
- 所需
- EORI number of importer/exporter; Importer's Russia-sanctions origin evidence file; Air waybill, inbound valuables consignment; Air waybill; Commercial invoice; Bar list (serials, weights, fineness)
- 出具
- CDS full import declaration
官方指引[conflict] gb.div-cpc-chief - VAT Notice 701/21 s.8.1 still gives CHIEF CPC 40 00 073; the tariff (28 Sep 2026) shows the exemption as additional code VATE. [not-read] The CDS procedure code and DE 1/10-1/11 entries for investment gold not read (UK Trade Tariff Vol. 3 listed in gb-fetch.tsv).
- 26
Account for import VAT: exempt for investment gold (additional code VATE); 20% standard rate (code 03020) on non-investment gold (dore, grain, scrap, sub-995 bars, non-qualifying coins); customs duty 0.00% (third-country rate on 7108 12, S.I. 2020/1430)
- 执行方
- Bullion dealer / trader (importer of record, usually an LBMA member)
- 所需
- CDS full import declaration
官方指引VAT Act 1994 Sch 9 Group 15; VAT Notice 701/21, Notice s8.1, s10.7
- 27
Clear the goods (CDS message when cleared), or ask for supporting documents for a customs check; for 7108 the Russia/Belarus measures read "Import allowed after control"; HMRC enforces trade sanctions at the border
- 执行方
- HMRC (customs and VAT authority)
- 所需
- CDS full import declaration
- 出具
- CDS clearance notification (goods released)
官方指引 - 28
Give the custodian written notice of the deposit (amount, Availability Date, and the carrier and packing for physical delivery, or the source account for book-entry); advise the vault manager of the vehicle registration and driver's identity
- 执行方
- Bullion dealer / trader (importer of record, usually an LBMA member)
- 所需
- CDS clearance notification (goods released)
- 出具
- Deposit notice to London custodian
标准LPMCL Allocated Account Agreement; LBMA Good Delivery Rules, Allocated cl. 3.3 (Unallocated cl. 3.2); GD Rules Annex B s.2
- 29
Weigh the bars under the London weighing procedures (the receiving party may charge for weighing if not weighed by an Approved Weigher) and produce the machine-readable, dated weight list stating whether an Approved Weigher weighed the metal; a copy travels with the bars
- 执行方
- LBMA Approved Weigher
- 出具
- Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
标准LBMA Good Delivery Rules, Annex B
- 30
Receive bars on pallets; before crediting, verify compliance with the Rules and weigh them per LBMA practice against the notified amount; the vault manager may refuse bars not meeting Good Delivery standards and may ask LBMA to appoint independent inspectors
- 执行方
- London commercial vault / custodian (typically a clearing or custodian bank)
- 所需
- Deposit notice to London custodian; Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
标准LPMCL Allocated/Unallocated Account Agreements; LBMA Good Delivery Rules, Allocated cl. 3.1(b), 3.4, 3.5; Unallocated cl. 3.1(b), 3.3, 3.4; GD Rules 2.4 and Annex B
- 31
For bars of the six suspended Russian refiners: accept only bars produced while the refiner was listed and already in the loco London/Swiss markets before 7 Mar 2022; clearing banks attest conformity
- 执行方
- London commercial vault / custodian (typically a clearing or custodian bank)
- 所需
- Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
标准Separately, UK law bans import of Russian gold exported from Russia on or after 21 Jul 2022. [unconfirmed] GD Rules 2026 s.1.4 says bars of a refiner moved to the Former List for sanctions reasons may lose Good Delivery status; LBMA's specific Russian-bars page keeps pre-7 Mar 2022 loco London/Swiss stocks as Good Delivery - the model follows the specific page.
LBMA Good Delivery List suspension notice (7 Mar 2022)
- 32
Credit the client: an allocated account (specific bars, title stays with client, weight list issued) or an unallocated account (a metal debt claim on the custodian); statements at least annually
- 执行方
- London commercial vault / custodian (typically a clearing or custodian bank)
- 所需
- Machine-readable LBMA weight list accompanying the delivery (dated, approved-weigher status)
- 出具
- Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement
标准LPMCL Account Agreements, Allocated cl. 2.3, 7.3 and Schedule (bar numbers, purity, gross and fine weight, brand); Unallocated cl. 1.1, 2.3, 3.3
- 33
Central-bank channel: hold Good Delivery bars in an allocated account at the Bank of England (off the Bank's balance sheet)
- 执行方
- Bank of England (gold custodian)
- 形态
- LBMA Good Delivery 400oz bar → Monetary gold (central bank reserve)
官方指引Monetary state applies when held as reserves by a monetary authority.
- 34
Report month-end holdings to LBMA (London vault data) and, from Dec 2026, aggregated vault data into the Gold Bar Integrity database (bar-level reporting planned from 2027)
- 执行方
- London commercial vault / custodian (typically a clearing or custodian bank)
- 出具
- Custodian holdings return to LBMA (London vault data / GBI)
标准 - 35
Onboard the counterparty: MLR customer due diligence and sanctions representations in the account agreement
- 执行方
- LPMCL clearing member bank
- 出具
- MLR customer due diligence file
法律原文[not-read] MLR reg 27 quoted via WebFetch; MLR not held.
MLR 2017; LPMCL account agreements, MLR reg 27; LPMCL Allocated cl. 10 / Unallocated cl. 8
- 36
Agree the OTC trade (spot/forward) under the 1994 International Bullion Master Agreement (IBMA) or an ISDA Master Agreement with the 1997 ISDA Bullion Definitions; LBMA Members must comply with the Global Precious Metals Code
- 执行方
- Bullion dealer / trader (importer of record, usually an LBMA member)
- 所需
- MLR customer due diligence file
- 出具
- OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997)
标准 - 37
Apply the VAT treatment: investment gold between LBMA members is zero-rated (TMO); gold held in the UK between central banks, or between a central bank and an LBM member, is zero-rated (VATA Sch 8 Group 10); investment gold between an LBMA member and a taxable non-member is standard-rated under the special accounting scheme (the buyer accounts for the VAT); to private individuals it is exempt; other investment gold is exempt unless the supplier has opted to tax; standard-rated gold (fine gold, grain, scrap, opted investment gold) between VAT-registered traders goes under the compulsory special accounting scheme
- 执行方
- Bullion dealer / trader (importer of record, usually an LBMA member)
- 所需
- OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997)
官方指引[conflict] gb.div-tmo-member-category. [not-read] TMO arts 3-7 and VATA s.55 not held; the member/non-member rule is from VGOLD1600 ("Supplies of investment gold between members and non-members who are taxable persons are now standard-rated") and Notice 701/21 ss. 11.2, 11.5.
VAT (Terminal Markets) Order 1973; VATA 1994 s.55, Sch 8 Group 10, Sch 9 Group 15
- 38
Settle loco London: book transfer between unallocated accounts through LPMCL members (client instructions by 16:00, inter-member by 16:30 London), or transfer of specific allocated bars
- 执行方
- LPMCL clearing member bank
- 所需
- OTC bullion trade confirmation (IBMA 1994 / ISDA Bullion Definitions 1997); Allocated weight list (bar number, gross weight, fineness, fine weight, brand) or unallocated balance statement
- 出具
- Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
标准Cut-offs (client instructions until 4.00pm, LPMCL members until 4.30pm London time) confirmed in the held 2017 OTC Guide; the current web section not held.
- 39
Pay the cash leg against metal settlement
- 执行方
- LPMCL clearing member bank
- 所需
- Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
- 出具
- Cash-leg payment for the metal
未经核实Cash-leg timing and DvP arrangements not documented in the sources read.
- 40
For exempt investment gold: issue an invoice with a unique number and the prescribed details for each sale over GBP 5,000 (or smaller sales once a customer passes GBP 10,000 in 12 months); keep the accounting and customer records (identity from one List 1 and one List 2 document) for at least 6 years; notify HMRC in writing within 28 days of the first exempt supply over GBP 5,000 or when supplies to one customer exceed GBP 10,000 in 12 months; failures attract a penalty normally of 17.5% of the transactions' value
- 执行方
- Bullion dealer / trader (importer of record, usually an LBMA member)
- 所需
- Loco London settlement: transfer between unallocated accounts via LPMCL members, or allocated bar transfer
- 出具
- Investment gold invoice (VAT tertiary legislation s.3 / VAT Regs reg 31A); Investment gold customer records and identity evidence; Notification to HMRC of exempt investment gold dealing (within 28 days)
法律原文Tertiary legislation (force of law, held). [unconfirmed] The general 6-year retention and the 17.5% penalty are in Notice 701/21 ss. 7.7 and 9.4, outside the passages marked as having force of law.
VAT Regulations 1995; VAT tertiary legislation (gold), reg 31A
- 41
Keep MLR records 5 years; nominated officer files a suspicious activity report where there is suspicion
- 执行方
- LPMCL clearing member bank
- 所需
- MLR customer due diligence file
- 出具
- Suspicious activity report to the National Crime Agency
官方指引MLR record-keeping regulation not held; 5 years from the end of the relationship or completion of the transaction per HMRC guidance.
税费
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
官方指引金额未确认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
官方指引金额未确认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
官方指引金额未确认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)
官方指引金额未确认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)
官方指引金额未确认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).
官方指引金额未确认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
官方指引
管制
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…
官方指引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)
法律原文金额未确认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)
法律原文金额未确认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.
法律原文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…
标准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 …
官方指引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…
标准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…
法律原文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
法律原文金额未确认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.
标准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
法律原文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…
法律原文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…
官方指引Customs and Excise Management Act 1979; VAT Notice 701/21 s.14
第 4 段:巴西
回到原产国:出口收益
- 42
Receive the foreign buyer's payment; the exporter may keep the foreign currency abroad or convert it through an FX contract
- 执行方
- Authorised institution exporting gold as a financial asset / exchange instrument
- 出具
- Foreign buyer's payment of export proceeds
法律原文Lei 11.371/2006 art. 1 as reworded by Lei 14.286/2021 art. 26; Resolução BCB 277/2022, Lei 14.286 art. 26; Res. 277 art. 46
国家之间的衔接
巴西 → 加拿大 已研究
随货跨境的文件: NF-e Ouro - remittance note (PCO to head office/refinery); Domestic refiner's bar list / certificate; NF-e Ouro - export of gold (financial asset / exchange instrument); Packing list; Air waybill; Consignment Security Declaration; e-DMOV de saída (gold as financial asset); RVES / RVFV - customs security-element and physical verification reports in the e-DMOV; Pre-shipment notification to refiner/buyer
加拿大 → 英国 已研究
随货跨境的文件: Commercial invoice from the foreign shipper; Commercial Accounting Declaration; Refiner outturn assay and settlement statement; Bar list of refined bars (GD 400 oz, 100 oz, kilobars); CERS export declaration and proof of report number; Air waybill