Whilst I may be mistaken, and I stand to be corrected, I think you will find that regulation 13.18AA is not law.
oh, and another thing. When you do the list that you submit showing what assets you hold, count everthing up and just put one line for silver...and 1 line for gold etc. don't go 1x pm 10oz bar 1x southercross 10oz bar 20x 2009 1oz kooks etc etc keep it SIMPLE: 40oz Silver It's all bullion.....trust me...keep it simple. My fund got compliant and I must have 10 different types of silver, bars/coins. But my holdings just state it has XXX oz silver..thats it. nice and simple.
See the sticky on GST http://forums.silverstackers.com/to...-tax-gst-on-precious-metals-in-australia.html
You are sorta correct ... It is a regulation made under the Act, so it has the force of the Act even though it's not IN the Act.... it's made pursuant to the Law with the force of the law. But it's not a Law, it's a Regulation. :lol:
If it is not law, then it could be argued, that there is no legal compulsion for the SMSF to comply with the ATO's advisory regulation.
Guys.... Sit back and relax.... Buying bullion has no GST. Hence I don't think it's not a collectible item. ATO only worry if you pay CGT when selling your bullion at higher the price. The fund is responsible to its beneficiaries, in this case, it's you and maybe your partner, too. As long as you don't use your superfund for current personal benefit, ATO wouldn't care too much. Your auditor/accountant wont even bother to see your bullion collection each year, why ATO bother how you store? ATO has too many staff?