Project area

Fiscal and credit

Working method

Vice President: Dario Bonauguri

The points will be set, analyzed, and defined by the FEDERORAFI Fiscal Group, which is composed of the subject matter experts present in the structures of the related Territories (Confindustria Alessandria, Confindustria Toscana Sud and Confindustria Vicenza) and in FEDERORAFI under the responsibility of Dr. Walter Marazzani (Federorafi). In addition to the Bullion Traders and Refiners Group, which will be periodically updated on relevant issues (not only fiscal but also others such as traceability), work will be done by periodically involving companies and/or experts potentially interested in the individual topic.

The proposed topics, divided between CREDIT AREA and FISCAL AREA, are as follows:


Continue to study and monitor the evolving dynamics of the gold loan contract or other instruments for financing the supply of the valuable raw material from both legal and fiscal perspectives.

Establishment of a Gold Loan Monitoring Committee composed of invited supply chain operators, officials from the banking system. Census of atypical gold loan contracts from both the banking side and the supply chain operators (bullion traders, refiners, and production companies). Verification of the situation also regarding the “Customs and Habits” of the Chambers of Commerce. Evaluation of the “non-possessory pledge,” whose regulation establishing the Registry, dated May 25, 2021, was published in the Italian Official Gazette on August 10, 2021. In the near future, this institution could be effectively used as an alternative instrument to gold loan and thus as an additional lever to increase opportunities for access to credit. Insights into other alternative instruments to gold loan which, necessarily, must go through the banking system: among the alternatives, a particular form of “trade credit insurance” will be evaluated.


Internal analysis about how to use the so-called “metal accounts”, in case of intervention of EU and Non-EU credit institutions, as the receiving party for the return of metal by the BT, metal originally received by it on account of processing; return by crediting the aforementioned “metal account” at the credit institution and in the name of the customer. Definition of “semi-finished product” for the purpose of tax treatment (“reverse charge”) and prompt response to the June 2021 FEDERORAFI query to MISE.
“Reverse Charge of supply chain” of jewelry: actions for inclusion within the transposition provisions of the “tax delegation law” that Parliament is preparing to grant to the Government for the reform of the national tax system. Use of tax leverage to enhance the use of EU online B2C sales (e.g.: the OSS – One Stop Shop – scheme, introduced from 1.07.21 for long-distance sales of goods shipped from one member state to final consumers in another EU member state and for services rendered to final consumers subject to VAT in the member state of consumption). Monitoring the opportunities emerging from the use of tax leverage with particular regard to the benefits attributable to the so-called “circular economy.”