2013-12-05 bullionrock 3
TRANSCRIPT
Taxation & Precious Metals
Tony Mancini
5 December 2013
HOW DO YOU HOLD YOURS?
© 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.
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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.
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DIRECT OWNERSHIP & PHYSICAL ASSETS
Gold Silver
Platinum Palladium
Metal = asset for capital gains tax
CGT on profit of sale
Chattel exemption may apply if an individual bar is sold for less
than £6,000
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.
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INVESTMENT FUND
Asset for CGT = interest in fund
Underlying investment less relevant
Open-ended offshore structure =
offshore income gain
Applies to companies and unit trusts
Precious Metal Fund
© 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.
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Transparent for tax purposes
Same as ownership and physical assets
PARTNERSHIP
Partnership
© 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.
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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)
Foreign coins = foreign currency
CG on exchange movements and actual gain• Krugerrands• US Eagle
© 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.
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BULLIONROCK GOLD FUND
BullionRock Gold Fund is a partnership.
Investors treated as owning gold coins.
Gold Britannias = legal tender
Investors are holding currency directly
No CGT on disposal of partnership interest
BRGF
Gold Britannias
© 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.
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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.
ContactTony Mancini
Executive Director, Tax
Tel: +44 (0) 1481 741845
Fax: +44 (0) 1481 722373
Email: [email protected]
Web: www.kpmg.com/channelislands
Thank you
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