In April 2026, something shifted for silver investors who buy through German bonded warehouses, and many will only notice the next time they want to top up. The German Federal Ministry of Finance redrew the VAT rules for customs warehouses in a letter of 9 April 2026, applicable to all open cases. The industry was taken by surprise; individual providers suspended new business in silver and technology metals the very same day.
To understand why this is a break, and why a Swiss or Liechtenstein vault is not touched by it, you have to step back briefly. And if you have not yet settled which location suits your situation, start one level higher: with the overview where to store precious metals.
Why silver sits in a customs warehouse at all
Gold and silver are treated completely differently for tax. Investment gold is exempt from VAT when you buy it, in the UK, across the EU and in Switzerland too. Silver, platinum and palladium are not. In the UK you pay the standard rate of 20 per cent when you buy, in Germany 19 per cent, in Switzerland 8.1 per cent.
For an investor, this tax is not a pass-through item but a real loss. You pay it on purchase and do not get it back on sale, because the dealer buys the metal back from you at its material value. On a six-figure silver position, that means five-figure sums gone on the day of purchase.
That is exactly why the customs warehouse established itself as the solution. Goods lying there count as not imported for tax purposes. Purchase, storage and sale take place without customs duty or VAT arising, as long as the metal does not leave the warehouse. Anyone who did not want to stack their silver in the living room anyway had a clean and entirely legal way of avoiding the tax.
What changed on 9 April 2026
The German letter ties the tax exemption in German bonded warehouses to a condition an investor as a rule does not meet: the supply is only exempt if you, or someone acting for you, actually ends the warehousing procedure, meaning the metal is formally imported or re-exported.
The ministry describes the investment case expressly. It concerns supplies to a customer who is an end consumer and where, as a rule, no import or re-export takes place, expressly including the acquisition of goods as a capital investment. The example in the letter is the investor who is credited in a storage account, receives a warehouse receipt and does not end the procedure until the sale. Result: the supply to him is taxable and liable to VAT.
The classic investment model does exactly this. The investor buys, the metal stays where it is, it is never physically moved. The step on which the exemption now depends is missing, and the purchase becomes liable to VAT.
Three things matter here:
- Investment gold is not affected. Investment gold has its own exemption, independent of all this. The letter itself does not mention precious metals at all; its only metal example is cobalt. In practice the shift hits silver, platinum, palladium, technology metals and rare earths.
- The change concerns German customs warehouses inside the EU. It is a German administrative instruction on VAT and does not reach into Switzerland.
- There is no transitional period. The rules apply to all open cases.
The one way out the letter leaves open
There is one arrangement in which the exemption survives, and the letter spells it out as an example: where the purchase contract stipulates that the buyer or their agent must take the metal out of the warehouse and import it on sale. Then the supply is tax-free at the moment of purchase, because the end of the procedure is fixed from the outset.
The catch: the price of that exemption is exactly what the model was meant to avoid. If you commit by contract to import the silver later, you also commit to paying tax on it later, as an import. The tax is postponed, not avoided.
That is the real finding behind the headline: for an investor who wants to buy metal and leave it lying, the German customs warehouse as a tax-free place is finished.
What happens to metal already bought there
Precision pays here, because the industry speaks loosely of grandfathering. What the letter actually says: the new rules apply to all open cases. For supplies made before the letter's publication, it will merely not be objected to if the supplying business treated them as tax-free.
In practice: if you bought before 9 April 2026, you need not expect your earlier purchase to be reopened. But the non-objection is addressed to the dealer and their VAT, not to you and your metal. It is an administrative concession, not a legal entitlement, and it covers only the past. Every top-up from now on falls under the new interpretation.
If you hold a position in a German customs warehouse, you face a very concrete question: topping up there is no longer tax-free. Either the position stays as it is and further metal is built up elsewhere, or the holding moves too. Both are a matter of arithmetic, not of faith, and the sum is worked through further down.
Why Switzerland and Liechtenstein stay out of it
A Swiss free port vault is subject to Swiss customs. Switzerland is not a member of the EU and not part of the EU customs territory. Liechtenstein has formed a common customs territory with Switzerland since the customs treaty of 1923 and, since the VAT treaty of 1994, a common VAT territory as well; the principality applies the substantive Swiss rules in parallel.
That has an unspectacular but decisive consequence: a change to German VAT guidance changes nothing about the treatment of metal lying in Zurich, Geneva or Vaduz. Nor does it touch you if you buy from the UK: your metal never enters the German system.
On top of that, Swiss law opens the same route from the other side. The supply of goods that were demonstrably under customs supervision in a free port vault and have not lost that status is exempt from tax. A sale within the free port vault therefore also remains free of VAT, as long as the metal does not leave the vault and keeps its customs status. The same applies to an open customs warehouse, there on condition that the procedure is properly concluded. In such a vault you can therefore still acquire silver, platinum and palladium at the net value of the goods and store them for an unlimited time, with no customs duty and no VAT.
Note the reasoning, because it carries further than the headline: the transaction is exempt not because a vault is tax-free as such, but because the goods have and keep their customs status. If they lose it, the exemption goes with it. For investment gold you do not need the vault for tax purposes anyway: transactions in gold for investment purposes of 995 thousandths and above, in bars bearing the stamp of a recognised assayer-melter and in state-minted gold coins, are exempt from tax in Switzerland, and so is the import of such gold. If you only want to store gold in Switzerland, you therefore need no free port vault and choose the vault by form of custody and security.
This is not a loophole and not a construction. It is simply the consequence of the goods never having been imported into a tax territory in which a tax could arise.
The point where it gets expensive
This is the mistake we most often have to correct in consultations. The tax is not waived, it is deferred.
As soon as you take the metal out of the free port vault and release it into free circulation, the charges fall due. If you take it out in Switzerland, that is Swiss VAT. If you have it brought to the UK, it is an import from a third country, with import VAT at the standard rate of 20 per cent on the full value of the goods; into an EU state, it is that state's import VAT.
So if you plan to bring your silver home at some point, you have saved nothing, only postponed. The model works for someone who genuinely wants to hold the position outside the reach of their own state over the long term. For everyone else it is the wrong solution, and that is something to know beforehand, not afterwards.
This is also the structural difference from Singapore. There, consumption tax on investment precious metals is not deferred; none arises. Once you have understood that difference, you choose the location for other reasons: storing precious metals in Singapore.
The 10,000 question, and why it almost only concerns gold
Almost every client asks us the same question: do I have to declare this at the border?
The answer is more precise than most expect. Under the EU cash regulation, gold at the EU's external borders counts in law as cash. Specifically, that covers gold bars, gold nuggets and gold clumps with a fineness of at least 99.5 per cent and gold coins with a gold content of at least 90 per cent. Anyone leaving or entering the EU with these worth €10,000 or more in total must declare it in writing, unprompted. Switzerland and Liechtenstein are third countries, so the external border rules apply in both directions.
Silver is a different matter. It is not cash under the EU regulation. Some states ask about it nonetheless: Germany treats silver and platinum as equivalent means of payment, which you must state orally when a customs officer asks. Jewellery and other goods made of precious metal, incidentally, count as neither.
Great Britain draws the line elsewhere. Its cash declaration from £10,000 does not cover gold except on journeys into and out of Northern Ireland. In England, Scotland and Wales, gold and silver are goods: above the £390 allowance you declare them, investment gold stays free of import VAT, and silver bears import VAT at 20 per cent.
All of this is entirely legal and done in fifteen minutes. Even so, it is the point at which most conversations get emotional. Hardly anyone fancies standing at a customs post with ten kilos of gold in the car, explaining origin and beneficial ownership and then sitting in a database. That is not a legal worry but a very human one. And you do not have to have it. How the reverse direction works in detail is on our page bringing gold into the UK.
Why organised transport is something other than a drive
If you take the metal across the border yourself, you are the person who declares. If a secure logistics firm takes over the transport, the customs formalities shift to the service provider.
In practice it works like this: the metal is first taken into a professional high-security vault in your home country; for clients from Germany that is usually Frankfurt. From there it travels as insured secure transport from vault to vault, to Switzerland, Liechtenstein or Singapore. You never touch the bars and you stand at no border. The full process, the insurance questions and the calculation of when this pays off compared with a sale are written up in transporting precious metals abroad.
For larger holdings this is also practically superior to the car boot. Four hundred kilos of silver fit into no travel luggage, and the insurance question cannot be cleanly solved on a private journey anyway.
The calculation most people get wrong
A client recently had a large silver position lying in Germany and wanted it in Singapore. His first thought was the obvious one: sell at home and buy again in the destination country.
That is almost always the expensive option, and the reason is the spread. You sell at one dealer's buying price and buy at another dealer's selling price. With silver, the gap between those two prices is considerably wider than with gold. On a large position, such a round trip quickly adds up to six figures.
Transporting the same four hundred kilos cost around €15,000. So he saved a six-figure sum by keeping the same metal instead of selling it and buying it back.
The point behind it is the same one that runs through all our work: moving is not selling. Ownership does not change, the position remains, only the place changes. A sale followed by a repurchase, by contrast, is a real economic transaction, with all the costs and tax consequences attached to it.
With smaller holdings, this calculation tips. Silver has a low value density, and transport and insurance cost per kilo regardless of the metal price. When a move pays off depends on the size of the position, on the metal and on the dealing spread you would actually pay. That sum is worth doing before you sell, not afterwards.
Segregated custody, not a pooled holding
For asset protection, one question matters more than tax: does a particular bar belong to you, or a share in a holding?
In segregated custody, also called allocated storage, the stored pieces are clearly assigned to you, with number and weight. In pooled custody you hold a claim against the custodian. In normal times you notice no difference. In the scenario for which people hold precious metals in the first place, it is the only difference that counts.
The same goes for whether your metal lies with a bank or outside the banking system. If you hold precious metals as a hedge against precisely the institutions that are closed in an emergency, you should not store them in their vaults.
What we do
We run neither vaults nor secure transport. Specialists do both, and that is how it should be.
What we do is the decision before that. Which jurisdiction suits your situation, which vault, which form of custody, in what form the metal should be held at all, and whether a move pays off compared with what you are planning right now. For the client above, exactly this calculation was the entire value of the consultation. Otherwise he would have paid a six-figure sum in dealing spreads to end up owning the same metal.
Then comes the question nobody likes to ask: what happens to it on inheritance, on divorce, on enforcement. A vault abroad is not an end in itself; it is part of a structure, and it should fit that structure.
If you are thinking about buying more silver, or want to take an existing position out of the country, that is exactly the conversation worth having before you sell anything.
👉 Book an appointmentFrequently asked questions
Can I still buy silver without VAT in a free port vault?
In a Swiss or Liechtenstein free port vault, yes. In a German bonded warehouse, practically no longer: since the German Finance Ministry's letter of 9 April 2026, the exemption there only applies if you, or someone acting for you, actually ends the warehousing procedure, meaning you import or re-export the metal. An investor who leaves the metal where it is does exactly not do that.
Are holdings bought in a German warehouse before 9 April 2026 affected?
The letter applies to all open cases. For supplies made before its publication, however, it will not be objected to if the dealer treated them as tax-free. In practice, earlier purchases are left alone, but this is a non-objection on the dealer's side, not a promised protection of existing holdings for the investor.
Is investment gold affected by the change?
No. Investment gold has its own, independent VAT exemption, in the UK, across the EU and in Switzerland. The shift hits silver, platinum, palladium and technology metals.
Do I pay Swiss VAT if I buy silver into a Swiss free port vault?
No. Goods that are demonstrably under customs supervision in a free port vault and do not lose that status can be supplied tax-free; the same applies to an open customs warehouse, provided the procedure is properly concluded. The 8.1 per cent on silver, platinum and palladium only arises when the metal is released into free circulation.
Do I have to declare gold at the Swiss border?
At the EU border, from 10,000 euros in total, yes, in writing and unprompted, in both directions: gold counts as cash there, meaning bars, nuggets and clumps of 99.5 per cent fineness and coins of 90 per cent gold content. Silver is not cash under the EU rules. Into Great Britain, gold and silver are goods: above your £390 allowance you declare them, and silver then bears 20 per cent import VAT.