An exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permit

This article aims to answer the question whether an income arising from financial instruments hedging foreign exchange risk, i.e. the income from forward contracts and currency options, can be considered as an income from an economic activity conducted on the basis of a Special Economic Zone (SEZ) P...

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Main Author: Dominika Wróblewska
Format: Article
Language:English
Published: Wydawnictwo Naukowe Uniwersytetu Mikołaja Kopernika 2020-12-01
Series:Prawo Budżetowe Państwa i Samorządu
Subjects:
Online Access:https://apcz.umk.pl/czasopisma/index.php/PBPS/article/view/PBPS.2020.024/28198
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author Dominika Wróblewska
author_facet Dominika Wróblewska
author_sort Dominika Wróblewska
collection DOAJ
description This article aims to answer the question whether an income arising from financial instruments hedging foreign exchange risk, i.e. the income from forward contracts and currency options, can be considered as an income from an economic activity conducted on the basis of a Special Economic Zone (SEZ) Permit or an economic activity specified in the decision on support. In the Author’s opinion, the income from contracts for the purchase or sale of foreign currencies constitutes the income from tax-exempt activities, provided that transactions were used to hedge foreign exchange risk related to activities specified in the SEZ Permit or the decision on support. This is a tantamount to the possibility of exempting such an income from corporate income tax. The empirical and analytical method was applied for the purpose of the analysis of legal acts regulating the discussed subject. Literature, individual interpretations of tax law, tax explanations, and judgments of administrative courts were used as well.
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institution Kabale University
issn 2300-9853
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language English
publishDate 2020-12-01
publisher Wydawnictwo Naukowe Uniwersytetu Mikołaja Kopernika
record_format Article
series Prawo Budżetowe Państwa i Samorządu
spelling doaj-art-2601fb03ee93482fb0f3b788d11c15dd2025-01-02T08:32:58ZengWydawnictwo Naukowe Uniwersytetu Mikołaja KopernikaPrawo Budżetowe Państwa i Samorządu2300-98532353-70862020-12-0184719410.12775/PBPS.2020.024An exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permitDominika Wróblewska0https://orcid.org/0000-0001-6805-0547University of Szczecin, PolandThis article aims to answer the question whether an income arising from financial instruments hedging foreign exchange risk, i.e. the income from forward contracts and currency options, can be considered as an income from an economic activity conducted on the basis of a Special Economic Zone (SEZ) Permit or an economic activity specified in the decision on support. In the Author’s opinion, the income from contracts for the purchase or sale of foreign currencies constitutes the income from tax-exempt activities, provided that transactions were used to hedge foreign exchange risk related to activities specified in the SEZ Permit or the decision on support. This is a tantamount to the possibility of exempting such an income from corporate income tax. The empirical and analytical method was applied for the purpose of the analysis of legal acts regulating the discussed subject. Literature, individual interpretations of tax law, tax explanations, and judgments of administrative courts were used as well.https://apcz.umk.pl/czasopisma/index.php/PBPS/article/view/PBPS.2020.024/28198special economic zonedecision on supportderivative financial instrumentscurrency riskexchange rate differences
spellingShingle Dominika Wróblewska
An exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permit
Prawo Budżetowe Państwa i Samorządu
special economic zone
decision on support
derivative financial instruments
currency risk
exchange rate differences
title An exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permit
title_full An exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permit
title_fullStr An exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permit
title_full_unstemmed An exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permit
title_short An exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permit
title_sort exemption from taxation of an income arising from financial instruments hedging foreign exchange risk in business activities conducted on the basis of a decision on support or in a special economic zone on the basis of a permit
topic special economic zone
decision on support
derivative financial instruments
currency risk
exchange rate differences
url https://apcz.umk.pl/czasopisma/index.php/PBPS/article/view/PBPS.2020.024/28198
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AT dominikawroblewska exemptionfromtaxationofanincomearisingfromfinancialinstrumentshedgingforeignexchangeriskinbusinessactivitiesconductedonthebasisofadecisiononsupportorinaspecialeconomiczoneonthebasisofapermit