Private ruling: GST - importation of silver
Date of advice: 29 May 2026
Published: 17 August 2026
Ruling period: DD MM 20YY to DD MM 20YY
Date scheme commenced: DD MM 20YY

Ruling: Q1: Is you importation of silver bullion coins (Coins) a non-taxable importation under paragraph 13-10(b) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act)? | A1: No. The Coins are not non-taxable importations under paragraph 13-10(b) of the GST Act as they are not considered to be in 'investment form'. They will therefore be considered taxable importations under section 13-5.

Relevant facts and circumstances: On xxxx, you purchased a collection of coins from a company in country A. You are registered for GST. Your GST registration relates to your activities as a sole trader, operating as a business consultant. This order was shipped with xxxx and they have informed you that you will be required to pay GST. xxxx have informed you that because you have paid over spot price, they will not be considered non-taxable importations. You have not claimed any input tax credits in relation to the GST that was claimed that you will be required to pay on the importation of the Coins. The spot price for Silver on 7 April 2026 was $108.16AUD.

Relevant legislative provisions: A New Tax System (Goods and Services Tax) Act 1999 section 9-5 | A New Tax System (Goods and Services Tax) Act 1999 section 13-5 | A New Tax System (Goods and Services Tax) Act 1999 section 13-10 | A New Tax System (Goods and Services Tax) Act 1999 section 38-325 | A New Tax System (Goods and Services Tax) Act 1999 section 40-100 | A New Tax System (Goods and Services Tax) Act 1999 section 195-1.

Reasons for decision: Summary: Paragraph 13-10(b) of the GST Act provides that an importation is a non-taxable importation if: ...it would have been a supply that was GST-free or input taxed if it had been a supply. To establish whether your importation of the Coins is a non-taxable importation, it is important to determine whether the supply of the Coins that you imported into Australia would have been a GST-free supply under section 38-385 or input taxed under section 40-100 of the GST Act had the supply been made in Australia. Section 38-385 provides that a supply of precious metal is GST-free if: (a) it is the first supply of that precious metal after its refining by, or on behalf of, the supplier; and (b) the entity that refined the precious metal a refiner of precious metal; and (c) the recipient of the supply is a dealer in precious metal. Note: Any other supply of precious metal is input taxed under section 40-100. Section 40-100 of the GST Act provides that a supply of precious metal is input taxed. For section 38-385 and section 40-100 of the GST Act to be applicable, the Coins imported must meet the definition of 'precious metal'. The term precious metal is defined in section 195-1 of the GST Act and means: (a) gold (in an investment form) of at least 99.5% fineness; or (b) silver (in an investment form) of at least 99.9% fineness... While the Coins you imported satisfy the minimum fineness requirements specified in the GST Act, they also need to be 'in an investment form' to satisfy the precious metal definition. While 'in an investment form' is not defined in the GST Act, the Commissioner has expressed his interpretation of the term in paragraph 14 and onwards in Goods and Services Tax Ruling GSTR 2003/10 Goods and services tax: what is 'precious metal' for the purpose of GSTR ( GSTR 2003/10). In particular, paragraph 29 in GSTR 2003/10 provides a summary of what constitutes 'in an investment form' and states: 29. To summarise the above, for gold, silver or platinum to be in an investment form for the purposes of the GST Act, it must be in a form that: • is capable of being traded on the international bullion market, that is, it must be a bar, wafer or coin; • bears a mark or characteristic accepted as identifying and guaranteeing its fineness and quality; and • is usually traded at a price that is determined by reference to the spot price of the metal it contains. Paragraphs 37 to 42 of GSTR 2003/10 specifically refers to coins and the differences between bullion coins from proof or other numismatic or collectors' coins. Relevantly paragraphs 37 and 38 in GSTR 2003/10 states: | Detailed Reasoning - Coins: 37. Gold, platinum or silver coins can be manufactured to two standards, namely proof and bullion quality. Proof coins are marketed as collectables, whilst bullion coins are for the trading market. 38. The major factors that differentiate bullion coins from proof or other numismatic or collectors' coins include the following: a) Bullion coins are traded on the basis of their metal content, whereas proof or other numismatic or collectors' coins are traded on the basis of their numismatic, commemorative or rarity value. The price of gold, silver or platinum bullion coins is determined by reference to the prevailing spot price of the gold, silver or platinum they contain. In the case of numismatic or other collectors' coins, their value varies in accordance with the supply and demand for these items based on their novelty and rarity, as well as being influenced by movements in the metal price. The price for individual numismatic coins is also influenced by the condition of the coin. The price for proof coins is determined in reference to the spot price and also the additional value arising from their physical characteristics; they are exact reproductions, without flaws. Whereas for bullion coins the stamping only establishes their worth in terms of their metal value - the stamping only guarantees their fineness and the backing of government as currency. For proof coins, the additional quality of the finish is not related to the fineness and quality of the metal, but adds a further value associated with the quality of the finish and condition; b) Bullion coins are mass produced and freely available. This enables them to be freely traded in world markets. In contrast, the minting of proof coins is limited; and c) Bullion coins are considered to be an alternative investment product to bullion bars and wafers. They are traded by many banks, bullion dealers, commodity brokers and stockbrokers. Proof coins and other numismatic or collectors' coins, on the other hand, are primarily traded by coin dealers. Paragraph 42 of GSTR 2003/10 explains that there are coins, such as commemorative coins, that are marketed in the retail market as 'bullion' coins because they are made from bullion. Such coins are not bullion coins for the purposes of GSTR 2003/10. Whether a coin is a precious metal does not depend on its label as a bullion coin, proof coin or numismatic coin. Instead, the determining factor is whether the coin has the inherent characteristics of gold, silver, or platinum, regardless of its name. | Detailed Reasoning - Your contentions: Your contentions are as follows: You cannot buy physical silver at spot price, dealers buy at the spot price and sell at a higher price, that's how they make a profit. If you were to purchase a.9999 silver bullion coin from your local bullion dealer (xxxx) you would have to pay between $137.95 & $156.18 (as of xxxx) and none of these products would have GST applied. All of the Coins meet the criteria for the silver to be in investment form: 1) Being coins, they are capable of being traded on bullion market. 2) They are all bear the mark ".9999 fine silver" 3) They are all bullion coins, and their value is based purely on silver content, you purchased them based on silver content, and when you come to sell them, you will only receive the value of silver. | Detailed Reasoning - Application to your case: All of the Coins must be examined in their own right as to whether they are in an investment form. 2024 1 oz xxxx • Manufacturer: Asahi Refining • Diameter: 39 mm • Purity: 99.9% On 7 April 2026, the average spot price for silver was AUD$108.16 per oz. On the same day, you purchased a 2024 1 oz xxxx coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is considered high. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD$xx to AUD$xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, the coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. The 2024 1 oz xxxx coin is described on the BullionStar website as a "true collector's delight", highlighting its collectability. The high-quality finish therefore contributes to its value, suggesting that the spot price is not the primary factor driving its price. Consequently, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2024 1 oz xxxx coin as a proof coin or collector's item. | Detailed Reasoning - 2023 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.9 mm • Thickness: 3.5 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2023 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2023 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2021 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.9 mm • Thickness: 3.5 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2021 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2021 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2022 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 4 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2022 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of gold coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2022 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2021 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 4 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2021 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2021 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2020 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 4 mm • Purity: 99.99% • Mintage: 500,000 On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2020 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2020 1 oz Silver xxxx Bullion Coin as a proof coin or collector's item.' | Detailed Reasoning - 2015 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 4 mm • Purity: 99.99% • Mintage: 500,000 On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2015 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2015 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2014 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 4 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2014 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2014 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2011 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 4 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2011 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2011 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2022 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 2.6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2022 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2022 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2020 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 2.6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $xx per oz. On the same day, you purchased a 2020 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2020 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2018 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 2.6 mm • Purity: 99.99% • Mintage: 300,000 On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2018 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2018 1 xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2015 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 2.6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2015 1 oz xxxx SIlver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2015 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2014 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 2.6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2014 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2014 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2011 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 2.6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2011 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2011 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2010 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 2.6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2010 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2010 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2009 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Perth Mint • Diameter: 40.6 mm • Thickness: 2.6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2009 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2009 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2026 2 oz xxxx Bullion Coin: • Country: X • Manufacturer: The Royal Mint • Diameter: 38.61 mm • Thickness: 6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $xx per 2 oz. On the same day, you purchased a 2026 2 oz xxxx Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2026 2 oz xxxx Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2025 2 oz xxxx Bullion Coin: • Country: X • Manufacturer: The Royal Mint • Diameter: 38.61 mm • Thickness: 6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $216.32 per 2 oz. On the same day, you purchased a 2025 2 oz xxxx Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2025 2 oz xxxx Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2024 2 oz xxxx Bullion Coin: • Manufacturer: The Royal Mint • Diameter: 38.61 mm • Thickness: 6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $216.32 per 2 oz. On the same day, you purchased a 2024 2 oz xxxx Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2024 2 oz xxxx Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2024 2 oz xxxx Bullion Coin: • Manufacturer: The Royal Mint • Diameter: 38.61 mm • Thickness: 6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $216.32 per 2 oz. On the same day, you purchased a 2024 2 oz xxxx Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2024 2 oz xxxx Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2023 2 oz xxxx Bullion Coin: • Manufacturer: The Royal Mint • Diameter: 38.61 mm • Thickness: 6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $216.32 per 2 oz. On the same day, you purchased a 2023 2 oz xxxx Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not deemed to solely derive from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2023 2 oz xxxx Bullion Coin as a proof coin or collector's item.' | Detailed Reasoning - 2025 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Royal Mint • Diameter: 38.61 mm • Thickness: 6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2025 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2025 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2023 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Royal Mint • Diameter: 38.61 mm • Thickness: 6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2023 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2023 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 2023 1 oz xxxx Silver Bullion Coin: • Manufacturer: The Royal Mint • Diameter: 38.61 mm • Thickness: 6 mm • Purity: 99.99% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 2023 1 oz xxxx Silver Bullion Coin for $xx resulting in a xx% premium above the spot price. While we acknowledge that a standard premium is added to the spot price of silver coins to account for profit and other costs, the purchase premium is significantly higher than the standard premium. Additionally, on the same day, and from the same seller, you purchased other 1 oz coins, paying prices ranging from AUD $xx to AUD $xx. The fluctuation in the prices for the same weight product demonstrates that in addition to the spot price, other characteristics contributed to determining the selling price. Although, your silver coin satisfies the fineness and quality requirements, it possesses other distinguishing characteristics. Features such as the coin's design, commemorative nature, novelty, rarity and high-quality finish contributes to its value, suggesting that the spot price is not the primary factor driving its price. Therefore, the coin's value is not solely derived from the metal itself but from its unique characteristics as a coin made from the metal. For these reasons, we consider the 2023 1 oz xxxx Silver Bullion Coin as a proof coin or collector's item. | Detailed Reasoning - 1 oz xxxx Silver Bullion Round (Pre-Owned in Good Condition): • Manufacturer: Geiger Edelmetalle • Purity: 99.9% On 7 April 2026, the average spot price for silver was $108.16 per oz. On the same day, you purchased a 1 oz xxxx Silver Bullion Round (Pre-Owned in Good Condition) for $xx resulting in a xx% premium above the spot price. The coin is listed as 'pre-owned in good condition' which indicates that the condition of the coin impacted on the selling price of the coin. Under subparagraph 38(a) of GSTR 2003/10 mentioned above, the price for individual numismatic coins are also influenced by the condition of the coin. Therefore, the coin shows characteristics of being numismatic in nature. For these reasons, we consider the 1 oz xxxx Silver Bullion Round (Pre-Owned in Good Condition) as a proof coin or collector's item. | Detailed Reasoning - Conclusion: It is considered that your acquisition of the Coins was due to features such as their design, commemorative nature, high-quality finish, novelty and rarity. This is further evident in the range of prices for the Coins purchased. The price of the Coins ranges from $ xx to $xx for all of the 1 oz coins. If the price was determined solely with reference to the spot price, there would not be the fluctuation in the prices for the same weight product. | Detailed Reasoning - All of the Coins that are 2 oz were purchased for the same price of $xx, however they were purchased at a significant premium to the spot price: On this basis, the Coins as a proof coin or collector's item and are not "in an investment form" and are not a precious metal for the purposes of the GST Act. Consequently, section 40-100 and 38-385 of the GST Act cannot apply and your importation of these coins into Australia is not considered a non-taxable importation under paragraph 13-10(b) of the GST Act. They are therefore a taxable importation under section 13-5 of the GST Act.