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

1. Taxation &
Precious Metals
Tony Mancini
5 December 2013

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.
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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.
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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.
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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.
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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
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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.
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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.
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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. © 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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complexity‟ are registered trademarks or trademarks
of KPMG International Cooperative (KPMG
International).