Treaty on Global Currency Transactions Tax

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Treaty on Global Currency Transactions Tax

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PART II Currency [Exchange] Transaction Tax

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TITLE V TAXABLE TRANSACTIONS

TITLE V TAXABLE TRANSACTIONS

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ARTICLE 8

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§1 "Currency Exchange Transaction" shall mean the exchange as owner of currency of a State for currency of another State.

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A Contracting State may consider the transactions from the perspective of both taxable persons in an exchange transaction to constitute one single transaction.

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§2 For the application of this article the Contracting States of the European Economic and Monetary Union or the States who have a single currency are considered to be a State.

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§3 "Currency of a State" shall mean the currency, bank notes and coins used as legal tender in a State with the exception of collection items; "collection items" shall be taken to mean gold, silver or other metal coins or bank notes which are not normally used as legal tender or coins of numismatic interest;

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§4 "Currency Exchange Transaction" shall also be taken to mean the exchange of currency pursuant to a contract under which commission is payable on the exchange. Where a person acting in his own name but on behalf of another takes part in a currency exchange transaction, he shall be considered to have received and supplied those currencies.

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§5 "Currency exchange Transactions" shall also be taken to mean transactions in financial instruments, or derivatives thereof, that have equivalent effect as exchange of currency, including exchange transactions of instruments that imply risks proper to the fluctuation in value of currency and including agreed mutual exchanges of assets, substituting for exchanges of legal tender.

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