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伴随金融市场的全球化进程,近年来跨境衍生品交易量在迅速增长。然而,为促进国内金融市场的经济效率和基于金融资产的流动性及资本的可替代性的考量,往往认为衍生品所得并无来源地税收的课征。然而,来源地税收是对进入和利用本国金融市场的物理性、法律和经济基础设施所征收的对价,单边放弃来源地课税反而会降低税收公平,对衍生品所得同样如此。因此,衍生品交易所得同样存在来源地征税的问题:柜台交易的衍生品交易所得以付款人居住地为来源地;上市交易的衍生品则以其上市的交易所所在地为收入来源地。
With the globalization of financial markets, the transaction volume of cross-border derivatives has been rapidly increasing in recent years. However, to promote the economic efficiency of domestic financial markets and based on the liquidity of financial assets and capital’s substitutability, there is often no source of revenue taxation on derivatives. However, the taxation of the source area is the consideration that is levied on the physical, legal and economic infrastructures that enter and utilize the domestic financial markets. Instead of taxing the sources unilaterally, it will lower the tax fairness. The same is true for the derivation of derivatives. Therefore, there is also the problem of source taxation on derivative transactions: Derivatives traded over the counter are sourced where the payer resides, and derivatives traded on the market derive their income from the location of the exchange on which they are listed.