Singapore VCC insights

Singapore vs Dubai Gold: GST, VAT, Vaulting and AML for a Family Portfolio

By VCC Editorial Team · Published 24 October 2026

Photo: Jingming Pan on Unsplash

Short answer: Both hubs take indirect tax off investment-grade bullion, but on different terms. Singapore exempts investment precious metals from GST and sets stricter purity and refiner tests. The UAE zero-rates them for VAT at 99% purity. Singapore also lets 13O and 13U funds hold physical gold without the old 5% cap from 1 August 2026.

Key facts at a glance

Singapore has exempted the import and local supply of investment precious metals (IPM) from Goods and Services Tax (GST) since 1 October 2012. Investment-grade gold must be at least 99.5% pure, silver at least 99.9% and platinum at least 99%.
The IRAS e-Tax Guide “GST: Guide on Exemption of Investment Precious Metals (IPM)” is in its twentieth edition, published 30 January 2026. Gold that does not qualify as IPM bears GST at 9%.
In the UAE, Article 36 of the Executive Regulation of Federal Decree-Law No. 8 of 2017 zero-rates the supply or import of gold, silver and platinum of 99% purity or more that is in a form tradeable in global bullion markets. The standard VAT rate is 5%.
UAE Cabinet Decision No. 127 of 2024 extended the reverse charge to precious metals and stones traded between VAT-registered businesses. It repealed Cabinet Decision No. 25 of 2018.
Under the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019, a Singapore dealer must file a cash transaction report where cash or a cash equivalent above S$20,000 is received. The report is due within 15 business days.
From 1 August 2026, MAS removed the 5% cap on physical investment precious metals under the tax incentive schemes for funds, which include the section 13O and 13U schemes.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

Families comparing Singapore vs Dubai gold tend to start with the vault’s reputation. For a family portfolio, the outcome turns on narrower questions. Does the bar or coin meet the local definition of investment metal? Who reports the purchase? Can a regulated family fund hold it and keep its exemption? What paperwork proves who owns which bars? This note compares the two hubs on those points only, with no view on the gold price. Every rule below was checked against Singapore and UAE government sources on 24 October 2026.

How does Singapore tax a family’s purchase of physical gold?

A purchase of qualifying investment gold in Singapore carries no GST, and neither does an import of it. Metal that fails any of the IRAS criteria is ordinary taxable goods and bears GST at 9%.

The exemption took effect on 1 October 2012. The criteria are in the Fourth Schedule to the Goods and Services Tax Act 1993 and explained in the IRAS e-Tax Guide on the exemption of investment precious metals (twentieth edition, 30 January 2026). A bar, ingot or wafer qualifies only if it meets all four tests:

Purity: gold of at least 99.5%, silver of at least 99.9%, or platinum of at least 99%.
Tradability: the refiner is on the current or former London Bullion Market Association (LBMA) Good Delivery list for gold and silver, or the London Platinum and Palladium Market (LPPM) list for platinum, or is endorsed by Enterprise Singapore while seeking that accreditation.
Quality mark: it bears an internationally accepted quality mark, such as an accredited refiner’s hallmark. Bank-branded bars from accredited refiners qualify.
Not decorative or collectable: bars with a hanger or hole, and odd shapes such as hearts or animals, are excluded.

Coins follow a closed list in the Fourth Schedule, for example the Canada Maple Leaf, China Panda and Singapore Lion in gold. Proof, numismatic and collector’s versions of those coins are taxable, so a mixed parcel can carry two tax treatments on one invoice.

For an exempt sale, IRAS requires an invoice showing, for each bar, the metal, weight, purity, refiner, serial number where applicable, and unit price, issued within 30 days of the supply. That invoice is also the cleanest evidence of title to specific bars, so it belongs in the family office’s permanent records.

How does the UAE treat investment gold for VAT?

The UAE applies a zero rate, not an exemption, to investment precious metals. Its purity test is a single 99% threshold for gold, silver and platinum.

VAT was introduced across the UAE on 1 January 2018 at a standard rate of 5%. Article 36 of the Executive Regulation of Federal Decree-Law No. 8 of 2017 (Cabinet Decision No. 52 of 2017, as amended most recently by Cabinet Decision No. 100 of 2024) provides that “the supply or import of investment precious metals shall be zero-rated”. Investment precious metals are gold, silver and platinum that meet two standards: a purity of 99% or more, and a form tradeable in global bullion markets. The UAE Ministry of Finance’s VAT overview lists “certain investment in grade precious metals” among its zero-rated sectors.

Trade between businesses is treated separately. Cabinet Decision No. 127 of 2024, announced by the Ministry of Finance on 10 January 2025, applies the reverse charge to precious metals and stones supplied between VAT-registered businesses, so the buyer accounts for the VAT. It replaced Cabinet Decision No. 25 of 2018, which covered only gold and diamonds. A family buying in its own name without UAE VAT registration will not normally use it.

Article 36 names no coins and has no separate exclusion for decorative pieces. The test for any item is purity plus a form “tradeable in global bullion markets”.

Singapore vs Dubai gold: how do the rules compare side by side?

The regimes agree on standard bullion bars and differ on lower-purity metal, collector items and reporting.

Point	Singapore	UAE (including Dubai)
Indirect tax on qualifying bullion	Exempt from GST (import and local supply); exports zero-rated	Zero-rated for VAT (supply and import)
Standard rate of GST or VAT	GST 9%	VAT 5%
Gold purity threshold	99.5%	99%
Silver purity threshold	99.9%	99%
Refiner test	LBMA or LPPM Good Delivery (current or former), or Enterprise Singapore endorsement	Form tradeable in global bullion markets
Coins	Closed list in the Fourth Schedule; proof and collector versions taxable	Purity and tradability standards; no named list in Article 36
Business-to-business mechanism	Not applicable to exempt IPM	Reverse charge between VAT-registered businesses (Cabinet Decision No. 127 of 2024)
Dealer cash reporting	Cash or cash equivalent above S$20,000	Transactions of AED 55,000 or more, per UAE Financial Intelligence Unit guidance
Fund tax wrapper	Physical IPM in 13O and 13U funds without the 5% cap from 1 August 2026	Outside the scope of this note

The purity gap is the practical trap. A 99% gold bar zero-rated in Dubai is below Singapore’s 99.5% threshold, so it is taxable goods if later imported into Singapore. Screen every bar’s purity and refiner before shipment.

What anti-money laundering checks apply when a family buys bullion?

In both hubs the dealer, not the buyer, carries the reporting duty. A family should still expect identity checks, source-of-funds questions and reporting of large cash or cash-equivalent purchases.

In Singapore, the statute is the Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act 2019, which took that full title from 1 May 2024 and is administered by the Registrar of Regulated Dealers. The Ministry of Law’s transaction-based requirements page states that a regulated dealer must carry out customer due diligence in the circumstances the Act prescribes and must not proceed if it cannot complete it. The dealer must file a cash transaction report with the Suspicious Transaction Reporting Office within 15 business days of a designated transaction. That includes a sale paid in cash or a cash equivalent exceeding S$20,000, and same-day sales to the same customer, or to people known to act for the same person, that together exceed S$20,000. Asset-backed tokens are also covered, which matters if a family holds gold through a token rather than allocated bars.

In the UAE, a strategic analysis published by the UAE Financial Intelligence Unit (UAEFIU) in October 2022 states that dealers in precious metals and stones must report suspicious transactions, and any transaction equal to or more than AED 55,000, to the UAEFIU. A dedicated dealer report was introduced on the goAML platform in June 2021. As that report dates from October 2022, check the dealer’s registration with the Ministry of Economy and the latest UAEFIU guidance at the time of purchase.

The practical lesson is the same in both hubs. Pay from an account in the purchasing entity’s own name, keep the due diligence correspondence, and make sure the stated source of wealth matches what the family’s bank holds. Our contingency plan for moving assets from Dubai to Singapore covers the banking side.

Can a 13O or 13U family fund hold physical gold after 1 August 2026?

Yes. Physical investment precious metals can be held inside a fund under section 13O or 13U of the Income Tax Act 1947 without the former 5% cap, from 1 August 2026.

At the MAS Annual Report media conference on 28 July 2026, the Managing Director of the Monetary Authority of Singapore (MAS) recalled that Deputy Prime Minister Gan Kim Yong had announced the removal of “the 5% cap on physical investment precious metals under the tax incentive schemes for funds”. He confirmed it would take effect from 1 August 2026, “giving eligible funds and family offices greater flexibility to invest in physical gold in Singapore”. The detail sits in Annex 3 (designated investments) of MAS Circular FDD Cir 05/2026. The circular PDF did not open for this review, so read the precious metals item there before relying on it for a specific holding.

For a family, income and gains from qualifying physical metal can now fall within the fund’s exempt income without a portfolio-wide ceiling, and a larger gold allocation no longer has to sit outside the fund. Our note on designated investments for 13O and 13U explains how the list works.

On 27 March 2026, MAS and the Singapore Bullion Market Association also set out focus areas for Singapore as a gold trading centre, including vaulting and logistics standards and a clearing system for large bar and kilobar gold. These are announced work streams, not completed rules.

How should a family structure custody and vaulting for gold?

Decide whether the family wants specific allocated bars or a claim on unallocated metal, then document ownership, storage costs and exit routes before the first purchase.

Singapore’s GST rules distinguish the two. Qualifying bars are exempt goods, while a contract for an unallocated commodity that does not lead to delivery is a separate exempt supply under paragraph 1(n) of Part 1 of the Fourth Schedule. Storage is a service, so a GST-registered Singapore vault’s fee generally carries GST: the IRAS worked example shows S$20,000 of local storage bearing S$1,800 of GST. In the UAE, Article 36 covers only the supply or import of the metal, so ask each vault how it charges VAT on its fees.

A Singapore import of IPM is exempt from import GST but still needs an exemption permit through TradeNet declaring the refiner or coin name and the purity. IRAS warns that a wrong declaration is an offence.

Ownership is where families most often slip. Bars bought by an individual and later held “for” a trust or company without a documented transfer leave a title gap that surfaces at death or divorce. Where a Singapore holding company holds the metal, Singapore Secretary Services can maintain the registers that evidence ownership.

What steps should a family take before buying gold in either hub?

Settle the holding entity, the eligibility test and the evidence file first. The purchase itself is the easy part.

Choose the owner (individual, trust, holding company or 13O or 13U fund) and minute the decision.
Screen the product. For Singapore, check purity against 99.5%, 99.9% or 99%, the refiner’s status and, for coins, the prescribed list. For the UAE, check 99% purity and bullion-market form.
Confirm dealer status. In Singapore, confirm the dealer is registered under the 2019 Act. In the UAE, confirm registration with the Ministry of Economy.
Pay from the owner’s own account, avoiding cash and third-party payments.
Collect a compliant invoice. Insist on refiner, serial numbers, weight, purity and unit price, and file it as the title document.
Fix custody terms: allocated or unallocated, storage fees and their tax, insurance, audit rights and release instructions.
Test fund eligibility. If a 13O or 13U fund will hold the metal, check the item in Annex 3 of FDD Cir 05/2026 and record the analysis in the fund’s annual evidence file.

Which hub suits which family?

Neither hub is better for every family. It depends on residence, what the family buys and whether the gold sits inside a regulated fund.

A Gulf-resident family buying standard bars and holding them personally will find Dubai’s zero rate and single 99% test straightforward, and it covers some metal that Singapore would tax. A family that runs, or plans, a Singapore single family office with a 13O or 13U fund now has a clear reason to hold gold in Singapore, where physical investment metal can sit in the fund without the old 5% ceiling. Splitting the allocation between hubs adds a second dealer, reporting regime and custody contract. For the wider picture, see our like-for-like Singapore vs Dubai tax calculation and Singapore vs Dubai corporate tax for a family holding company.

Frequently asked questions

Is gold GST-free in Singapore?

Only investment precious metals are. Gold bars, ingots and wafers of at least 99.5% purity from an accredited or endorsed refiner, and coins on the prescribed list, are exempt. Jewellery, scrap, proof coins and decorative bars bear GST at 9%.

Will a 99% gold bar bought in Dubai be exempt if moved to Singapore?

No. Singapore’s threshold for gold is 99.5%, so a bar below that level is not an investment precious metal in Singapore and is taxable goods on import.

Does the S$20,000 cash transaction report apply to bank transfers?

The cash transaction report covers cash or a cash equivalent exceeding S$20,000 received by a regulated dealer. A dealer’s other duties still apply to a bank transfer, including customer due diligence in the circumstances the Act prescribes and suspicious transaction reporting.

Can a 13O fund hold more than 5% of its portfolio in physical gold?

Yes. From 1 August 2026, MAS removed the 5% cap on physical investment precious metals under the tax incentive schemes for funds. Check the precise item in Annex 3 of MAS Circular FDD Cir 05/2026 for the definition that applies.

Sources

Raffles Corporate Services helps family offices and fund managers set up the holding companies, VCCs and 13O or 13U fund vehicles that hold assets such as physical gold, and keeps their ongoing compliance in order. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 24 October 2026. The Editorial Team, Variable Capital Companies Act.