Source Based Taxation

Jurisdiction

Source Based Taxation, within cryptocurrency, options, and derivatives, fundamentally centers on the geographic location where value is created, irrespective of the taxpayer’s residency. This contrasts with residency-based taxation, where tax obligations stem from where an individual or entity is domiciled. For digital assets, determining the ‘source’ of income can be complex, often linked to the location of nodes validating transactions, the exchange facilitating the trade, or the location of the counterparty in a derivative contract. Consequently, cross-border transactions and decentralized finance (DeFi) present significant challenges to consistent application of this principle.