Purpose, roles and investment precious metals
The twelfth edition published 30 January 2026 explains ARCS under GST Act section 37B and General Regulations regulation 46A. Approved Refiners process/extract investment precious metals (IPM) or mint qualifying coins; Approved Consolidators aggregate gold, silver/platinum-containing materials for specified refiners. Domestic IPM imports/supplies are exempt, while supported exports are zero-rated. IPM means qualifying gold, silver or platinum bars, ingots, wafers or coins meeting the separate IPM guide’s criteria. ARCS adds import suspension, restricted inter-ARCS goods-payment waiver and special input recovery; each differs by role.
Toll refining and buy-sell models
Toll refining leaves materials and refined IPM owned by the customer; the refiner charges processing consideration. Buy-sell refining acquires the materials and sells its own resulting IPM, normally incorporating refining cost in the price. A customer’s simple delivery/return of goods is not necessarily a supply. Locally delivered toll-refining output bears GST on the refining fee even between ARCS persons; exported output can support zero-rated refining with export evidence. A buy-sell local IPM sale is exempt. Scrap, residues and non-IPM outputs have separate disposal treatment.
Approved Refiner: five import-suspension routes
A refiner may suspend GST for own business goods, including assets/inventory/materials; overseas-principal imports as section 33(2) agent for supply/export; section 33A imports for subsequent re-export; overseas-customer consigned materials for refining into IPM or precious metals; and qualifying section 33B reimports after overseas value-added work for local or registered overseas customers. For 33(2), 33A and overseas-customer consignment, the overseas person must be unregistered or OVR pay-only. Section 33B applies to registered overseas customers other than OVR pay-only persons, with its separate eligibility rules. Other-person or non-business imports outside those routes cannot use ARCS.
Refiner’s local-goods payment waiver
An Approved Refiner can supply business goods to another Approved Refiner or Consolidator without collecting/accounting GST. The transaction remains standard-rated: supplier reports Box 1 and customer taxable purchases Box 5, with no output/input tax. Verify the customer on IRAS’s ARCS list, issue a tax invoice and annotate Goods supplied under ARCS. If choosing to charge GST instead, obtain the ARCS customer’s agreement and keep a written undertaking. Local IPM remains exempt under its own rules, not a taxable supply newly converted by ARCS.
Refining is excluded from the waiver
Processing another person’s goods is treated as a goods supply for GST, but IPM exemption specifically excludes refining, and ARCS payment waiver also excludes it. In the source example, Refiner A’s non-IPM granules sold to Consolidator B receive waiver, whereas A’s toll-refining fee to Consolidator C for IPM delivered locally bears 9% GST. Export-related refining may be zero-rated with evidence. Do not infer that calling a processing fee “goods” makes it waiver-eligible.
Refiner’s full input recovery and claim timing
Approved Refiners may claim all input incurred for business under normal claim conditions, except disallowed regulations 26/27 expenses, regardless of toll or buy-sell model. Disallowed examples include club fees, medical/accident insurance, medical costs, family benefits and motor-car expenses. With full recovery, refiners do not apply reverse charge to imported services/LVG. Normally claim by tax-invoice date; a consistently used later posting/processing date is allowed with original invoices at claim and controls preventing duplicates. Full recovery is therefore not permission to claim unsupported or statutorily blocked costs.
Consolidator import suspension: direct refining intention
A Consolidator can suspend imports only of own goods or goods consigned by an overseas unregistered/OVR-pay-only person that will be directly supplied/delivered to a refiner for IPM or precious-metal refining. Here “refiner” includes approved and other local/overseas refiners, so qualifying export to an overseas refiner can apply. There must already be a standing refining arrangement and, for consignment, overseas instructions before import. Keep instructions, delivery orders and export evidence. If delivery might instead go to another local person or instructions are pending, pay import GST; own office fixed assets also fall outside the consolidator route. Recovery of tax paid depends on ordinary input or valid 33(2)/33A conditions.
Consolidator examples and its narrower waiver
Consolidator D imports overseas customers’ metals under an existing long-term arrangement with Refiner E and can suspend GST. Consolidator F imports circuit boards/materials pending instructions that might direct them elsewhere, and imports computers: neither qualifies. A consolidator may waive GST only on goods supplied to an Approved Refiner, not to another Consolidator or other local person. Report waived goods as standard-rated Box 1 with no tax; the refiner reports taxable purchase Box 5 with no input tax. The supplier’s role matters, even where both parties appear on the ARCS list.
Non-bank consolidator: first sale versus resale
Direct input for taxable supplies and the first sale of newly refined IPM can be recovered fully. “First sale” is immediately after refining, not every later resale. Under toll refining, the consolidator owns the output and its next sale can be first sale. If it instead sells scrap to the refiner and buys resulting IPM back, the refiner’s sale is first sale; consolidator resale is not. Eligible direct first-sale costs include raw material purchase/import, acquisition/storage/transport, refining fees and delivery of new IPM. Direct costs of ordinary exempt IPM resale cannot be claimed; costs shared with first-sale activity become residual input.
Non-bank residual formula and exclusions
Multiply residual input plus input for Regulation 33 exempt supplies by (taxable supplies + first sale of newly refined IPM) ÷ total supplies, rounding the ratio to the nearest whole percentage. Recovery is for the consolidator’s own relevant supplies. Exclude overseas customers’ IPM re-export values, customer-accounting receipts and reverse-charge imported services/LVG from both numerator and denominator, even when reported in the return. A consolidator without full recovery may need reverse charge on imported services from 2020 and LVG from 2023; the taxable-attribution scope exclusions follow the applicable reverse-charge rules.
Bank consolidators
Banks have a concession for full input on precious-metal purchase/import regardless of purity, not related insurance/storage/refining services. For an Approved Consolidator bank it continues where metals are refined into IPM or sold as non-IPM; all other permitted expenses, including refining, transport and overhead, use the bank’s fixed recovery rate. A non-ARCS bank cannot use that full-recovery concession for metal acquired to refine into IPM for its later sale, though non-IPM resale purchases/imports remain covered. Distinguish physical-metal tax from accompanying service tax.
Refiner qualification and coin-minting alternative
A qualifying refiner must be on current LBMA Good Delivery for gold/silver or LPPM for platinum, or be a new Singapore refiner endorsed by Enterprise Singapore to achieve that accreditation within the endorsed period. Newly refined IPM/refining-service supplies must exceed 50% of total: the examples’ combined 80%, 90% and 65% qualify, but 30% does not. A separate route for minting IPM coins requires taxable supplies plus newly refined IPM to exceed 95% of total; below 95% may be considered case by case. Exclude overseas-customer toll-refined IPM re-export and customer-accounting/reverse-charge values from relevant total-supply tests.
Consolidator qualification and control standards
The consolidator must directly supply/deliver materials for IPM refining to a current LBMA/LPPM refiner or an Enterprise Singapore-endorsed Singapore refiner at the supply date. Provide a standing-relationship contract, undertaking or supplier acknowledgement. Maintain inventory/accounting controls following goods through import, inter-ARCS delivery, refining and customer supply. Good IRAS and Customs compliance includes timely returns and all GST/income/property/withholding-tax obligations. Complete ASK or commit to ACAP; divisionally registered entities review the whole entity. Individual approval may add conditions such as a guarantee.
Application, ACAP and ongoing approval
Apply with GST F27B for refiners or F27A for consolidators, business activities/arrangements/parties and supply-chain/movement diagrams, endorsement if accreditation pending, and consolidator relationship evidence. Submit a certified ASK Section 3 declaration and retain working templates unless accepted for ACAP. Withdrawal or failure of ACAP requires ASK certification within six months; valid ACAP can use PAR F28 or renewal F29. Remaining in ARCS without renewing ACAP requires second PAR and certified F28A, performed/certified by an SCTP-accredited GST professional. IRAS states an outcome within a month, may inspect premises or require a guarantee. Eligibility and individual approval-letter conditions must continuously hold.
Own IPM, non-IPM and free disposals
Local IPM sales are exempt Box 3; documented exports are Box 2. If business IPM is given free after input was allowed on it or production materials, paragraph 8.3 requires deemed exempt supply at market value in Box 3. Own non-IPM local sale/residue disposal follows normal GST; no-consideration disposal normally uses market value, with normal exceptions for gifts costing no more than S$200 or no allowed acquisition input. Appendix 1’s consolidator summary says free IPM has no reporting, broader than paragraph 8.3. Do not use that abbreviated line to override the main paragraph’s conditional own-business-IPM rule; confirm the applicable facts if making such a gift.
Overseas-customer goods and the earlier delivery tax point
Account overseas customers’ local IPM sales as own exempt supplies at their selling price; merely returning or gifting their IPM requires no supply reporting. Non-IPM local sales are taxable on consideration; free disposal uses market value with a concession where value is no more than S$200. For those overseas-owned non-IPM goods, tax point is the earliest of delivery, receipt or invoice, not just invoice/payment. Documented exports of IPM/non-IPM go in Box 2, using consideration if any or market value for consigned exports. Fulfil the customer’s instructions and distinguish a sale from simple custody delivery.
GST reporting by transaction
Suspended refiner/consolidator imports are Boxes 5 and 9. Exempt IPM imports/local purchases have no purchase reporting. Paid local non-IPM/service purchases are Box 5 and allowable input Box 7; ARCS-waived purchase has value in Box 5 without Box 7 tax. Mere receipt/delivery of customer goods, including toll-return, is not a reportable purchase. Local refining fees are Boxes 1/6 and qualifying export refining Box 2. Own/overseas-client local IPM sales are Box 3. Waived eligible non-IPM sales are Box 1 without Box 6. Taxable non-IPM disposal is Boxes 1/6 and export Box 2. Consolidator first-sale expenses are Box 5 with allowed Box 7 input. Apply the main-text ownership qualifications to free goods.
Loss of eligibility and cessation timing
Regularly check own and relevant refiners’ continuing accreditation/approval. Notify the Comptroller in writing within 30 days of becoming ineligible; it will state cessation’s effective date. Paragraph 8.15 describes benefits ending from the day after the 30-day awareness period: imports require payment permits, inter-ARCS goods lose waiver, and normal input apportionment applies. A customer must immediately alert its ARCS supplier of ineligibility. Continue duties through effective cessation and complete overseas-owned-goods instructions first. Failure to report within 30 days can trigger retrospective repayment from a date imposed by the Comptroller; the stated period is not permission to conceal a lost condition.
Incorrect privileges, corrections and penalties
Incorrectly suspended imports require unprompted repayment of import tax that ordinary rules would not allow as input, reported as output in the import period, with no new input claim; if already filed, correct using GST F7, subject to applicable correction concessions. A supplier wrongly waiving goods or refining GST corrects the supply period for full output tax. An ineligible customer failing to notify repays waived tax that would not normally be recoverable, as output in the supply period; invoice date may be used administratively. Excess input claims require F7 correction of the affected period. Section 59 incorrect-return penalties and other misuse penalties can accompany repayment.
Permits, agents and continuing validity
Use relevant MES permits in TradeNet with IN-NON-PAYMENT (INP), Approved Premises/Schemes (APS) and receipt code ARCS. For IPM imports use an Exemption permit instead of MES. Appoint/manage at most 20 declaring agents through myTax Portal, using Corppass GST Tax Matters preparer/approver authority, and remain accountable for all their permits. ARCS lasts while conditions remain fulfilled and can be periodically audited; ACAP normally reduces checks unless significant anomalies occur. Contact IRAS GST through Contact Us; the edition lists Customs +65 6355 2000/customs.gov.sg for IPM permit matters.
Deregistration obligations
Before GST deregistration automatically ends ARCS, complete customer-contract obligations and hold no remaining ARCS customer goods. Own taxable imported assets/stocks, excluding IPM, over S$10,000 at the last registered day can require final deemed output tax. Goods imported under sections 33(2), 33A or reimported under 33B follow the respective guide’s exit rules. Do not dispose of consigned goods as if they were owned assets merely to clear the books.
Appendix 2: March 2024 supplies and attribution
The bullion consolidator reports S$6 million: local non-IPM sales S$1 million, reverse-charge services S$500,000, own exports S$2 million, overseas-customer IPM return exports S$1 million, own first-new-IPM sales S$500,000, ordinary IPM resale S$500,000 and overseas-client local IPM delivery S$500,000. Its direct recoverable input is A S$72,000 + D S$4,500 + F S$1,800 = S$78,300. E S$900 local-IPM-resale transport is disallowed; B exempt IPM purchase has no GST and C direct-refining imports have suspended GST. The table retains all ten expense classifications.
| Item | Cost | Input tax in source | Recovery |
|---|---|---|---|
| A | Non-IPM purchase S$800,000 | S$72,000 | Direct: taxable/first sale; full |
| B | IPM purchase/import | No GST | No input |
| C | Imports directly delivered for refining | Suspended | No input tax paid |
| D | Refining fee S$50,000 | S$4,500 | First-sale direct; full |
| E | Local resale-IPM transport S$10,000 | S$900 | Direct exempt; none |
| F | Export-IPM storage S$20,000 | S$1,800 | Direct taxable; full |
| G | Mixed IPM/non-IPM transport S$10,000 | S$900 | Residual |
| H | Office rent S$500,000 | S$45,000 | Residual |
| I | Share-issue legal fees S$50,000 | S$4,500 | Regulation33 input in formula |
| J | Reverse-charge imported IT services | S$40,000 as printed | Residual; source discrepancy explained |
Appendix 2: residual calculation and source discrepancy
The source excludes S$1 million overseas return exports and S$500,000 reverse-charge services from reported supply totals, giving denominator S$4.5 million and numerator S$3 million taxable plus S$500,000 own first sale. S$3.5m/S$4.5m rounds to 78%. It computes (G S$900 + H S$45,000 + I S$4,500 + J S$40,000) × 78% = S$70,512, then total S$78,300 + S$70,512 = S$148,812. However its J input is S$40,000 against S$500,000 imported services in a 9%-rate 2024 example, rather than S$45,000. These figures faithfully explain the printed calculation, not a reconciled 9% tax computation. Check the actual invoice/tax period; do not adopt the inconsistent amount as a rate rule.
Amendment chronology
The 2013 revision aligned eligibility/recovery with regulations; 2014 introduced repayment rules effective 1 January 2014 and clarified first sale/33B changes for January 2015. Later updates addressed declaring agents, 2020 reverse charge/OVR, SCTP naming and accreditation links, 2023 low-value goods and 8% examples, and 2024 9%. January 2026 clarified ASK/ACAP application/renewal. Historical commencement dates remain distinct from the latest cover date.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
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