abc bullion, page-18

Thanks.

The closest I have to Australian based advice is the tax summary in the PDS for our ASX listed produt http://www.perthmint.com.au/investment_gold_asx.aspx

Note this product is legally structured as a fully paid option, but the advice does say that physical settlement is not CGT event. We don't have any specific advice around unallocated conversions to physical.

Note that the unallocated conversion to physical is processed as a sell & buy for system reasons, it does not mean that internally we executed them as separate transctions (this is obvious as the spot price for both transactions should be the same). The net cash effect of the transction is the fabrication premium only, so this may help in arguing against a CGT event.

However, the ATO may take the view that the legal nature of unallocated is materially different to allocated/physical product. Maybe converting a 20oz bar into two 10oz bars may be considered like-for-like and thus not a CGT event, but the open question is how unreasonable will the ATO be.

Logically I would argue that unallocated to physical is much like withdrawing cash from a bank account - you are changing the "form" but not the underlying nature of the "investment" - it is still gold and your exposure (gain or loss) to that asset (gold) has not changed.

You may find http://www.perthmintbullion.com/Blog/Blog/10-12-14/Tax_Issues_When_Exchanging_Precious_Metals.aspx of use, but note the Solari report it links to is US based.