Brazil [financial-asset gold (BCB-authorised institution)] → South Africa (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。
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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) ⟶ 南非 (Doré bar - unstamped → LBMA Good Delivery 400oz bar) ⟶ 英国 (LBMA Good Delivery 400oz bar)
未研究:巴西 → 南非
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:南非
途经
Doré bar - unstamped → LBMA Good Delivery 400oz bar
- 9
Onboard the foreign depositor: KYC pack, mined-material questionnaire, refining agreement; apply LBMA Responsible Gold Guidance / OECD due diligence
- 执行方
- Refining-licence holder (refinery)
- 出具
- Refiner KYC pack on foreign depositor; KYC questionnaire for mined material; Refining agreement with depositor
行业惯例Rand Refinery states KYC and conflict-free sourcing policies; its depositor requirements and the RGG text were not read in this pass.
- 10
Hold a current SADPMR permit to import unwrought precious metal (Form PMI: quantity, fineness, form, value, period, ports, countries of origin, purpose)
- 执行方
- Refining-licence holder (refinery)
- 所需
- SADPMR refining licence; SAPS police clearance certificate
- 出具
- SADPMR permit to import precious metals
法律原文Precious Metals Act; Precious Metals Regulations, s.10(1)-(2); regs 21-22
- 11
Ship dore by air to Johannesburg with the origin country's export authorisation, export declaration and assay
- 执行方
- Foreign mine or exporter depositing doré
- 所需
- Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority); Export customs declaration accepted by the dispatching country's customs; Assay certificate (fineness and fine weight); Air waybill
- 出具
- Air waybill, origin to Johannesburg (OR Tambo)
未经核实[unconfirmed] PMA s.10(2)(b) requires the importer to declare and prove the origin of the metal in the permit application, and s.10(4) says the permit states the origin; which origin-country documents must accompany each shipment is not stated in any text read. The listed hand-off kinds are the model's route logic.
- 12
Enter the doré for customs with SARS on a bill of entry for import (the metal must be duly entered for customs under reg 21(4)(b)); entry may be refused if the Regulator considers it of dubious origin or incorrectly declared (reg 21(5))
- 执行方
- Refining-licence holder (refinery)
- 所需
- SADPMR permit to import precious metals; Air waybill, origin to Johannesburg (OR Tambo)
- 出具
- SARS import declaration for dore
法律原文[not-read] Customs and Excise Act procedure, tariff heading 7108 and import VAT on doré not read (Act not held). Manual C(G): gold import applications are referred to SADPMR.
Precious Metals Regulations; Customs and Excise Act 1964, reg 21(4)(b), 21(5)
“A precious metal may be refused entry into the South Africa if - (a) that precious metal is in the opinion of the Regulator of dubious origin; or (b) that precious metal has been incorrectly described or declared.”
- 13
Carry the dore from the airport to the refinery with the reg 26 waybill; SADPMR or SAPS may inspect imported metal
- 执行方
- Secure carrier of precious metal
- 出具
- Waybill, port of entry to refinery
法律原文Precious Metals Act, s.10(3), s.13; reg 26
- 14
Submit specimens of the imported metal to the SAPS Forensic Science Laboratory
- 执行方
- Refining-licence holder (refinery)
- 出具
- Specimen submission (importer)
法律原文Precious Metals Act, s.22(1)
“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.”
- 15
Weigh, melt, sample and assay each lot on receipt; issue outturn (final assay and fine weight) to the depositor
- 执行方
- Refining-licence holder (refinery)
- 所需
- Refining agreement with depositor
- 出具
- Refiner outturn / assay report
行业惯例 - 16
Refine at the licensed premises and cast 400 oz Good Delivery bars, kilobars (995-999.9), minted bars (10/50/100 g, 999.9) or grain
- 执行方
- Refining-licence holder (refinery)
- 出具
- Refiner bar list for bars produced
- 形态
- Doré bar - unstamped → LBMA Good Delivery 400oz bar
法律原文Precious Metals Act; Precious Metals Regulations, s.7(1), 7(5); reg 28 (minted bars)
- 17
Record receipts and outputs in the PMR2 register within 24 hours
- 执行方
- Refining-licence holder (refinery)
- 出具
- PMR2 refinery register entry / quarterly copy
法律原文Precious Metals Act, s.15(1); reg 33
- 18
Publish annual responsible-gold / LBMA compliance report
- 执行方
- Refining-licence holder (refinery)
- 出具
- Refiner responsible gold / LBMA compliance report
行业惯例 - 19
Credit fine gold to the depositor's metal account and hold the bars in the refinery vault pending sale or export
- 执行方
- Refining-licence holder (refinery)
- 所需
- Refiner outturn / assay report; Refiner bar list for bars produced
- 出具
- Metal account credit / settlement confirmation
行业惯例Rand Refinery lists vault and logistics services; account terms not seen.
- 20
Obtain Treasury permission and, for any unwrought or semi-fabricated output, SADPMR export approval; file the customs export declaration for the refined bars
- 执行方
- Refining-licence holder (refinery)
- 所需
- Refiner bar list for bars produced; SADPMR export approval for gold (PMA s.12); National Treasury approval to export gold (Exchange Control Reg 3; PMA s.12(1))
- 出具
- SARS customs declaration / bill of entry for export
法律原文[unconfirmed] No SADPMR or SARB text specific to re-export of refined foreign-origin gold was found; Reg 3, Manual C(B) and PMA s.12 are applied as written.
Exchange Control Regulations; Precious Metals Act, Reg 3; s.12(1)
- 21
Ship the bars to the depositor's buyer or vault abroad
- 执行方
- Secure carrier of precious metal
- 出具
- Waybill, refinery/exporter to port of export; Air waybill, Johannesburg to destination
法律原文Precious Metals Act, s.13; reg 26
税费
VAT on other domestic supplies of gold
15% Domestic gold supplies not zero-rated (e.g. recycled gold to banks; sales to traders)
法律原文金额未确认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)
法律原文金额未确认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
法律原文金额未确认Precious Metals Regulations, Annexure A as substituted by GN R737 (GG 38014, 22 Sept 2014)
管制
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
法律原文金额未确认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…
法律原文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)).
法律原文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…
官方指引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…
法律原文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.
法律原文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…
法律原文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)…
法律原文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.
法律原文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).
法律原文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…
法律原文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.
行业惯例LBMA Responsible Gold Guidance
Unwrought or semi-fabricated gold may not be carried outside a mine or refinery boundary without the prescribed waybill.
法律原文Precious Metals Act; Precious Metals Regulations, s.13; reg 26
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 → 南非 未研究
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
南非 → 英国 已研究
随货跨境的文件: SADPMR permit to import precious metals; Air waybill, origin to Johannesburg (OR Tambo); SARS import declaration for dore; Waybill, port of entry to refinery; Refiner outturn / assay report; Refiner bar list for bars produced; SARS customs declaration / bill of entry for export; Waybill, refinery/exporter to port of export; Air waybill, Johannesburg to destination
文件缺口
za.st-23 expects Assay certificate (fineness and fine weight); the earlier legs don't model this paper
交接说明
za.st-23: Origin country's export authorisation for the gold (permit, licence or clearance issued by the mining or trade authority) is not issued by Brazil by law