2013-12-05 bullionrock 3

Taxation & Precious Metals

Tony Mancini

5 December 2013

HOW DO YOU HOLD YOURS?

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HOW DO YOU HOLD YOURS?

Physical Ownership

Investment Fund

Partnership

Coins

BullionRock Gold Fund

VAT

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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

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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: amancini@kpmg.guernsey.gg

Web: www.kpmg.com/channelislands

Thank you

© 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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