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
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2013-12-05 BULLIONROCK 3
- 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. 1
- 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. 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. 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. 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. 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. 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. 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. The KPMG name, logo and „cutting through complexity‟ are registered trademarks or trademarks of KPMG International Cooperative (KPMG International).
Notas del editor
- 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.