Private ruling: GST - importation of coins
Date of advice: 16 April 2026
Published: 29 June 2026
Ruling period: 1 July 20YY to 30 June 20YY
Date scheme commenced: 1 July 20YY

Ruling: Q1: Is your importation of 20YY XX 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: Yes. The purchase of the Coins is a non-taxable importation under paragraph 13-10(b) of the GST Act.

Relevant facts and circumstances: On xxxx, you purchased xxxx (the Coins) from a company which is situated in Country 1. The tax invoice for your purchase quotes a market price for silver but does not provide a detailed commentary on the condition of the coins - such as circulated; uncirculated; grading, such as you would expect if these were factors to determine the sale price. Consequently, you imported the silver coins into Australia. The Coins were assessed as collectable items by Customs and you paid the GST on the importation. The Coins are silver coins minted by the XX Mint in State 1 as a XX run of X00,000. You contend that in accordance with the Australian Taxation Office (ATO) Goods and Services Tax Ruling 2003/10 - Goods and Services Tax: What is 'precious metal' for the purposes of GST? (GSTR 2003/10), these coins qualify as precious metals and consequently should be exempt from GST. In support of your argument, you have made the following submission: • You purchased the Coins from overseas and imported them into Australia for home consumption; • The Coins meet the definition of precious metals as they are 99.9% pure silver; • The coins are stamped with weight, metal type and purity; • The Coins are mass-produced internationally recognised investment XX. • A mintage of X00,000 is a standard XX production run and therefore not a rare numismatic release. • These coins are traded globally at a price determined strictly by the intrinsic daily spot price of silver plus a standard XX manufacturing premium.

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 13-15 | A New Tax System (Goods and Services Tax Act) 1999 section 38-385 | 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. The supply of the coins to you will not be the first supply of the 'precious metal' after its refining. Therefore, it will not satisfy subsection 38-385(1) of the GST Act and is not a GST-free supply of precious metal. 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... 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 their 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 XX 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 XX 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 XX quality. Proof coins are marketed as collectables, whilst XX coins are for the trading market. 38. The major factors that differentiate XX coins from proof or other numismatic or collectors' coins include the following: a) XX 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 XX 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 XX 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) XX 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) XX coins are considered to be an alternative investment product to bullion bars and wafers. They are traded by many banks, XX 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 'XX' coins because they are made from XX. Such coins are not XX coins for the purposes of GSTR 2003/10. Whether a coin is a precious metal does not depend on its label as a XX 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. The Coins you imported are capable of being traded on the international market and are minted by the State 1 Mint. As such, these coins bear a hallmark that is accepted as identifying and guaranteeing fineness and quality. The purchase order for the purchase of the coins references the market price of silver, thus indicating that your acquisition of the Coins was determined by the spot price of the metal it contains. The purchase order does not provide a detailed commentary on the condition of the coins - such as circulated; uncirculated; grading, such as you would expect if these were factors to determine the sale price. Further to this, X00,000 of the Coins were minted, which you have contended is a standard XX production run and therefore not a rare numismatic release. Paragraph 38(b) of GSTR 2003/10 refers to that the minting of proof coins is limited. We consider that your acquisition of the Coins was not due to features such as design, commemorative nature, high-quality finish, novelty and rarity. On this basis, the Coins are "in an investment form" and are a precious metal for the purposes of the GST Act. Consequently, your importation of the coins would meet the conditions of section 40-100 and your importation of these coins into Australia is considered a non-taxable importation under paragraph 13 10(b) of the GST Act.