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Taxation &
Precious Metals
Tony Mancini
5 December 2013
HOW DO YOU HOLD YOURS?
Physical Ownership
Investment Fund

Partnership
Coins

BullionRock Gold Fund
VAT
© 2013 KPMG Channe...
DIRECT OWNERSHIP & PHYSICAL ASSETS

 Metal = asset for capital gains tax

Gold

Silver

 CGT on profit of sale
 Chattel...
INVESTMENT FUND

 Asset for CGT = interest in fund

 Underlying investment less relevant

Precious Metal Fund

 Open-en...
PARTNERSHIP

 Transparent for tax purposes

Partnership

 Same as ownership and
physical assets

© 2013 KPMG Channel Isl...
COINS

Coins that are legal
tender = currency
asset for CGT

British coins are
not an asset for
CGT:
• Gold Britannia
• Si...
BULLIONROCK GOLD FUND

BullionRock Gold Fund is a
partnership.
Investors treated as owning gold
coins.
BRGF

Gold Britanni...
VAT ON PRECIOUS METALS

Precious Metals sold by EU/UK
business liable to VAT.
Investment Gold is exempt from VAT
in UK (in...
Thank you
Contact
Tony Mancini
Executive Director, Tax
Tel: +44 (0) 1481 741845

Fax: +44 (0) 1481 722373
Email: amancini@...
© 2013 KPMG Channel Islands Limited, a Jersey
Company and a member firm of the KPMG network of
independent member firms af...
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2013-12-05 BULLIONROCK 3

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How Do You Hold Yours?
Slides from the BULLIONROCK breakfast seminar held on 5 December.
Tony Mancini, Head of Tax, KPMG Guernsey

Published in: Economy & Finance, Business
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  • The Government intend consult with a view to introduce the following reforms to the non-dom regime:Remove the tax charge when non-domiciles remit foreign income or capital gains to the UK for the purpose of commercial investment in UK businesses;Simplify some aspects of the current tax rules for non-domiciles to remove undue administrative burdens; Increase the existing £30,000 annual charge to £50,000 for non-domiciles who have been UK resident for 12 or more years and who wish to retain access to the beneficial tax regime (the remittance basis). The £30,000 charge will be retained for those who have been resident for at least seven of the past nine years and fewer than 12 years.The Government will consult on the introduction of a statutory definition of residence to provide greater certainty forTaxpayers with the intention to implement the measure from April 2012.
  • Transcript of "2013-12-05 BULLIONROCK 3"

    1. 1. Taxation & Precious Metals Tony Mancini 5 December 2013
    2. 2. HOW DO YOU HOLD YOURS? Physical Ownership Investment Fund Partnership Coins BullionRock Gold Fund VAT © 2013 KPMG Channel Islands Limited, a Jersey Company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. 1
    3. 3. DIRECT OWNERSHIP & PHYSICAL ASSETS  Metal = asset for capital gains tax Gold Silver  CGT on profit of sale  Chattel exemption may apply if an individual bar is sold for less than £6,000 Platinum Palladium  Watch out for “trading” © 2013 KPMG Channel Islands Limited, a Jersey Company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. 2
    4. 4. INVESTMENT FUND  Asset for CGT = interest in fund  Underlying investment less relevant Precious Metal Fund  Open-ended offshore structure = offshore income gain  Applies to companies and unit trusts © 2013 KPMG Channel Islands Limited, a Jersey Company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. 3
    5. 5. PARTNERSHIP  Transparent for tax purposes Partnership  Same as ownership and physical assets © 2013 KPMG Channel Islands Limited, a Jersey Company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. 4
    6. 6. COINS Coins that are legal tender = currency asset for CGT British coins are not an asset for CGT: • Gold Britannia • Silver Britannia • Gold Sovereigns (post 1837) © 2013 KPMG Channel Islands Limited, a Jersey Company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. Foreign coins = foreign currency CG on exchange movements and actual gain • Krugerrands • US Eagle 5
    7. 7. BULLIONROCK GOLD FUND BullionRock Gold Fund is a partnership. Investors treated as owning gold coins. BRGF Gold Britannias Gold Britannias = legal tender  Investors are holding currency directly  No CGT on disposal of partnership interest © 2013 KPMG Channel Islands Limited, a Jersey Company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. 6
    8. 8. VAT ON PRECIOUS METALS Precious Metals sold by EU/UK business liable to VAT. Investment Gold is exempt from VAT in UK (includes investment gold coins). Silver Coins not exempt but collectors‟ items qualify for reduced rate of 5%. No VAT in Guernsey. © 2013 KPMG Channel Islands Limited, a Jersey Company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. 7
    9. 9. Thank you Contact Tony Mancini Executive Director, Tax Tel: +44 (0) 1481 741845 Fax: +44 (0) 1481 722373 Email: amancini@kpmg.guernsey.gg Web: www.kpmg.com/channelislands
    10. 10. © 2013 KPMG Channel Islands Limited, a Jersey Company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International Cooperative (KPMG International).
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