Key legal question
Whether the imported gold bars qualify for import tax exemption as bank gold.
Extracted holding
No. The bars lacked the required mark of an acknowledged refiner-assayer, so the exemption for bank gold did not apply.
Extracted reasoning
Art. 44 and 113 MWSTV must be read in harmony with the precious-metals control rules. For gold bars, the foreign assay recognition in Art. 178 EMKV requires both minimum fineness and the refiner-assayer's mark. A certificate cannot replace that mark.