Taxation of Derivative Financial Instruments

It would be difficult, in the mid-1990s, to identify a more pressing subject for discussion among tax and financial professionals than the appropriate treatment of derivative financial instruments.

<p class=copymedium>Given this, it is fitting that the 1995 Cannes Congress of the International Fiscal Association took a first, hard look at derivatives. In its description of DFIs, the Report adopts a three-dimensional analysis, expanding to the following enquiries:

<li class=copymedium>What is the nature of the transaction being considered?
<li class=copymedium> Who is the taxpayer?
<li class=copymedium>What aspect of taxation is being considered?

<p class=copymedium>The 29 National Reports survey both existing tax rules relating to DFIs and the sources of guidance that might be expected to shape the development of future rules.