## FINTECH NOTES — Taxing Stablecoins (Introduction and Excerpt)

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### Introduction: principles, scope, and approach
- Neutrality is presented as a fundamental principle of good tax law design: tax systems should generally strive to be neutral so that economic decisions are not distorted by tax considerations.
- Most jurisdictions have based their approach to taxing transactions involving crypto assets on neutrality.
- Crypto assets are defined as "private digital assets that depend primarily on cryptography and distributed ledger or similar technology (Financial Stability Board 2020, 5)."
- Stablecoins are defined as crypto assets that "aim to maintain a stable value relative to a specified asset or to a pool of assets, such as sovereign currencies (International Monetary Fund 2021, 41; Financial Stability Board 2020, 5)."
- Central Bank Digital Currencies are excluded from discussion: they are "digital forms of fiat money issued by central banks—capable of being legal tender—and as such can be treated for tax purposes exactly like traditional currencies."
- Methodological approach:
  - Jurisdictions typically rely on first principles in domestic tax legislation to approximate neutrality with comparable conventional transactions or activities.
  - Achieving neutrality requires a proper understanding of facts on a case-by-case basis; this is difficult given:
    - the nature and versatility of crypto assets;
    - the crypto industry's distinctive operations;
    - rapid evolution of underlying technology; and
    - inherent global reach beyond any single jurisdiction.
- Policy context and international stance:
  - G7 and G20 finance ministers and central bank governors have repeatedly stated that "no so-called global stablecoins should commence operation until all relevant legal, regulatory, and oversight requirements are adequately addressed through appropriate design and by adhering to applicable standards."
  - Many jurisdictions are reviewing and considering enhancements to legal and regulatory regimes to address risks arising from growth in crypto-related activities.
  - Updates by the IMF’s Statistical Department and the UN Statistical Committee planned for 2025 will address the statistical treatment of crypto assets.
- Key introductory conclusions:
  - Without greater tax certainty and neutrality than is currently available, stablecoins are unlikely to be more widely adopted as a means of payment, even if they prove to be more stable in value compared to other crypto assets.
  - Mismatches in tax treatment between jurisdictions create opportunities for arbitrage and abuse; more international cooperation and coordination are needed to address these.
  - Clarity on tax treatment is required regardless of whether the value of a particular stablecoin is appreciating or depreciating, because taxpayers and tax administrations need certainty about the appropriate tax treatment of both gains and losses.
- Organization of the Note:
  - Part I: overview of stablecoins, including a taxonomy of known types of stablecoins in circulation.
  - Part II: examines key value-added tax (VAT) issues specific to stablecoins.
  - Part III: discusses key income and capital gains tax implications for transactions involving stablecoins.
  - Part IV: conclusion.
- The Note "does not attempt to provide an exhaustive overview of current country practices or approaches, nor of all possible VAT or income tax issues that may arise from transacting in stablecoins—an exercise that would go beyond what can be covered in a Note of this kind."

### I. Overview and taxonomy of stablecoins
- Functional definition and distinctions:
  - Stablecoins seek to mitigate crypto volatility by linking or “pegging” their values to another asset or a pool of assets (for instance, the US dollar, precious metals, or another crypto asset).
  - Distinction between “pegging” (value linked to an underlying asset or pool) versus “backing” (issuer or third party sets aside assets and coin holders have some claim to those assets).
  - Reference assets can be on-chain (another crypto asset) or off-chain (traditional currencies, commodities); a stablecoin can be backed by multiple asset types.
- Examples cited:
  - Tether (Tether Limited), TrueUSD (TrustToken), USD Coin (Centre consortium—Circle and Coinbase), Gemini Dollar (Gemini)—pegged to the US dollar and purportedly backed one-for-one.
  - PAX Gold (Paxos Trust Company)—each token “redeemable” for and “backed” by one fine troy ounce of London Good Delivery gold stored in London vaults.
  - Dai (Maker Protocol)—decentralized, uses Ether to maintain value.
  - Kowala’s kUSD—algorithmic unbacked stablecoin that adjusts supply via market “oracles.”
  - SGA (Saga)—pegged to IMF SDR basket, backed by reserves in different currencies and assets including cryptocurrencies.
- Typology (authors’ compilation):
  - Backed (on- and off-chain assets) vs. Unbacked (algorithmic).
  - Recourse to asset vs. No recourse to asset.
  - Hybrid combinations exist.
- Functional considerations and uses:
  - If price stability and large user networks are achieved, stablecoins could serve as efficient retail or cross-border payment methods and as stores of value.
  - Stablecoins can also be used as speculative financial instruments.
- Regulatory overlap:
  - A given stablecoin arrangement may fall under multiple regulatory regimes (money laundering, securities, banking, fund management, financial infrastructure), but tax law generally requires a single or predominant classification.

### II. VAT/GST treatment of stablecoins
- VAT and money—general principles:
  - Most VAT systems do not separately tax the supply of money used as payment for goods/services by treating such supply as “out of scope” or excluded from “supply.”
  - Money-exchange transactions (currency swaps) are usually recognized as supplies but are typically VAT-exempt.
  - Distinction matters: exempt supplies reduce input tax credit entitlement and are reportable, while out-of-scope supplies typically are not.
  - Numismatic or collector money that has intrinsic value is usually taxable as a supply of goods.
- Key jurisprudence and country approaches:
  - CJEU (Skatterverket v. David Hedqvist, Case C-264/14): exchange of traditional currencies for nontraditional “moneys” (e.g., Bitcoin) in return for a spread fee is a VAT-exempt financial transaction if (1) accepted by parties as an alternative to legal tender and (2) has no purpose other than to be a means of payment.
  - Australia (2017 GST amendment): supplies of “digital money” when used for payment are treated the same as supplies of currency (not a supply for GST). Australia’s definition excludes units that (1) are denominated in any country’s currency; (2) have value derived from something else; or (3) give entitlement to receive or direct supply of particular things unless incidental.
  - Singapore (effective January 1, 2020): digital payment tokens are treated as currency for GST; exchanging tokens for traditional currencies is GST-exempt. Proposed definition similar to Australia’s but excludes tokens that (1) give entitlement to receive or direct supply of goods/services and (2) cease to function as a medium of exchange after entitlement used. IRAS guidance: tokens pegged to or backed by fiat, baskets, commodities, or other assets should be treated as derivatives and GST-exempt financial services (IRAS 2022, paragraph 5.7).
- VAT treatment implications specific to stablecoins:
  - Under Australia and Singapore approaches, pegging to another asset/currency means stablecoins are treated as derivatives (exempt) rather than money (out of scope), creating substantive and compliance VAT implications.
  - Under the CJEU approach, pegging does not automatically preclude money treatment provided subjective acceptance and objective single-purpose as means of payment are satisfied.
  - Pegging to non-sovereign assets raises VAT leakage/avoidance risk because underlying commodity supplies might otherwise be taxable; low entry barriers to token issuance exacerbate this risk.
  - Policy rationales:
    - Australia/Singapore: restrict money classification to counter potential VAT leakage and avoidance.
    - CJEU: focus on subjective use and objective function; avoids a strict pegging prohibition but may reduce tax certainty.
- Hybridity and voucher-like tokens:
  - CJEU objective test denies money-like VAT treatment to tokens that also serve other purposes (pure payment token requirement).
  - Australia’s “incidental benefits” test is less strict—incidental nonpayment features do not preclude digital currency status.
  - Singapore’s “means of payment” test is the most permissive—token qualifies if it can be used as medium of exchange after nonpayment entitlement is used; IRAS StoreX example shows multifunctional tokens can result in nontaxation of an underlying supply.

### III. Income and capital gains tax implications
- Income tax and money—general principles:
  - A supply of money for goods/services typically does not constitute a separate income tax gain/loss when money is used as medium of exchange.
  - Numismatic or investment money used in barter is treated as property; gains/losses computed separately on disposal.
  - Transactions denominated in a currency different from the taxpayer’s functional currency give rise to foreign exchange gain/loss issues—nature (capital vs. revenue) and timing (realization vs. period-end recognition).
- Current practice and operational challenges:
  - Majority of jurisdictions effectively treat crypto assets as property even when used as means of payment:
    - US IRS treats crypto assets as property.
    - Australia does not treat crypto used as means of payment as (foreign) currencies for income tax.
    - UK HMRC states current cryptoassets are not money or currency.
  - Treating stablecoins as property means each payment using a stablecoin is a realization (barter) triggering tax consequences—substantially increasing compliance burden compared with traditional currency payments.
  - Timing mismatch: income tax systems often allow end-of-period recognition for foreign exchange gains/losses, whereas property disposal rules apply per transaction—this can create different tax burdens depending on payment medium and market movements during the tax period.
- Classification nuances and examples:
  - Fully backed, redeemable stablecoin for a single traditional currency (e.g., one token for $1) arguably functionally similar to electronic money and could be treated similarly for tax purposes if market practice supports that.
  - Unbacked algorithmic stablecoins could be argued to operate like fiat currency if their “monetary policy” is algorithmically enforced.
  - Asset-backed stablecoins (on-chain or off-chain) raise ambiguity: could be negotiable promissory notes (representative money) or proprietary interests; examples include MakerDAO collateralized debt positions (overcollateralized, margin-call dynamics).
  - Pegged-but-not-directly-backed designs (e.g., Diem reserves accessible via authorized resellers) likened to forex-based ETFs; ETF interests might be proprietary and not money.
- Administrative and international coordination issues:
  - Subjective-use tests (treat as money if used as primary medium of exchange) present evidentiary problems and tax uncertainty.
  - Proposed administrative solution: a rebuttable presumption that stablecoins are money, with antiavoidance backstops; presumption not to apply if stablecoin is not regulated/supervised in the jurisdiction as deposit, e-money, or means of payment expressible in official monetary unit.
  - Cross-border mismatches can create double taxation or double nontaxation scenarios when jurisdictions adopt differing classifications.
  - Effective residence-based taxation of capital gains may require exchange of information with the issuer’s jurisdiction—problematic for decentralized stablecoins and peer-to-peer transactions without centralized intermediaries.
  - OECD’s Crypto-Asset Reporting Framework (CARF, 2022) aims to complement CRS by enabling exchange of information on crypto-asset transactions via reporting by defined crypto asset service providers; EU proposes DAC8 for crypto assets.

### IV. Conclusion — key takeaways and policy directions
- Certainty and predictability in tax treatment are prerequisites for stablecoins to become a convenient alternative means of payment domestically and cross-border.
- Clear taxpayer guidance from tax administrations can achieve much, but the multiplicity of token economic functions may necessitate nuanced or case-by-case approaches.
- To be competitive with traditional currencies, stablecoins predominantly used as means of payment require substantially similar tax treatment to currencies—VAT/GST systems show some movement in this direction, but income tax and capital gains tax treatment lag behind.
- Greater international coordination and cooperation are needed:
  - On substantive tax treatment to avoid cross-border tax arbitrage.
  - On tax administration and enforcement to equip tax authorities with tools to ensure domestic compliance (including exchange of information mechanisms).
- Greater consistency in regulatory treatment of stablecoins would help create a common reference framework to inform tax policy and administration.
- Without greater tax certainty and neutrality, stablecoins risk being unable to fulfill their promise as alternative means of payment; existing gaps and mismatches between jurisdictions may create distortions and opportunities for abuse.

*FINTECH NOTES — Taxing Stablecoins, INTERNATIONAL MONETARY FUND (excerpt).*

### Introduction ...........................................................................................................

### Introduction

### Principle of tax neutrality
- Neutrality is presented as a fundamental principle of good tax law design: tax systems should generally strive to be neutral so that economic decisions are not distorted by tax considerations.
- Most jurisdictions have based their approach to taxing transactions involving crypto assets on neutrality.1

### Definition and scope
- Crypto assets are defined as "private digital assets that depend primarily on cryptography and distributed ledger or similar technology (Financial Stability Board 2020, 5)."2
- This Note focuses specifically on stablecoins, a category of crypto assets that "aim to maintain a stable value relative to a specified asset or to a pool of assets, such as sovereign currencies (International Monetary Fund 2021, 41; Financial Stability Board 2020, 5)."
- Central Bank Digital Currencies are excluded from discussion: they are "digital forms of fiat money issued by central banks—capable of being legal tender—and as such can be treated for tax purposes exactly like traditional currencies."5

### Methodological approach: first principles and case-by-case analysis
- Jurisdictions typically rely on first principles in domestic tax legislation to approximate neutrality with comparable conventional transactions or activities.3
- Achieving neutrality requires a proper understanding of facts on a case-by-case basis; this is difficult given:
  - the nature and versatility of crypto assets;
  - the crypto industry's distinctive operations;
  - rapid evolution of underlying technology; and
  - inherent global reach beyond any single jurisdiction.
- Similar challenges exist in other areas of law and regulation, including regulatory/supervisory design and statistical treatment of crypto assets.4

### Policy context and international stance
- G7 and G20 finance ministers and central bank governors have repeatedly stated that "no so-called global stablecoins should commence operation until all relevant legal, regulatory, and oversight requirements are adequately addressed through appropriate design and by adhering to applicable standards."2
- Many jurisdictions are reviewing and considering enhancements to legal and regulatory regimes to address risks arising from growth in crypto-related activities.4
- Updates by the IMF’s Statistical Department and the UN Statistical Committee planned for 2025 will address the statistical treatment of crypto assets.4

### Main conclusions highlighted in the Introduction
- Without greater tax certainty and neutrality than is currently available, stablecoins are unlikely to be more widely adopted as a means of payment, even if they prove to be more stable in value compared to other crypto assets.
- Mismatches in tax treatment between jurisdictions create opportunities for arbitrage and abuse; more international cooperation and coordination are needed to address these.
- Clarity on tax treatment is required regardless of whether the value of a particular stablecoin is appreciating or depreciating, because taxpayers and tax administrations need certainty about the appropriate tax treatment of both gains and losses.

### Organization of the Note
- Part I: overview of stablecoins, including a taxonomy of known types of stablecoins in circulation.
- Part II: examines key value-added tax (VAT) issues specific to stablecoins.
- Part III: discusses key income and capital gains tax implications for transactions involving stablecoins.
- Part IV: conclusion.
- The Note illustrates discussion with representative country practices but "does not attempt to provide an exhaustive overview of current country practices or approaches, nor of all possible VAT or income tax issues that may arise from transacting in stablecoins—an exercise that would go beyond what can be covered in a Note of this kind."6

*International Monetary Fund — FINTECH NOTES: Taxing Stablecoins (Introduction).*

### Part IV concludes the

### Part IV concludes the discussion.

### I. Overview and Taxonomy of Stablecoins
- Stablecoins are a subcategory of crypto assets that seek to mitigate crypto volatility by linking or “pegging” their values to another asset or a pool of assets (for instance, the US dollar, precious metals, or another crypto asset).
- Distinction: “pegging” (value linked to an underlying asset or pool) versus “backing” (issuer or third party sets aside assets and coin holders have some claim to those assets).
- Stablecoin reference assets can be on-chain (another crypto asset) or off-chain (traditional currencies, commodities); a stablecoin can be backed by multiple asset types.
- Examples given in the text:
  - Tether (Tether Limited), TrueUSD (TrustToken), USD Coin (Centre consortium—Circle and Coinbase), Gemini Dollar (Gemini)—pegged to the US dollar and purportedly backed one-for-one.
  - PAX Gold (Paxos Trust Company)—each token “redeemable” for and “backed” by one fine troy ounce of London Good Delivery gold stored in London vaults.
  - Dai (Maker Protocol)—decentralized, uses Ether to maintain value.
  - Kowala’s kUSD—algorithmic unbacked stablecoin that adjusts supply via market “oracles.”
  - SGA (Saga)—pegged to IMF SDR basket, backed by reserves in different currencies and assets including cryptocurrencies.
- Stablecoin typology (authors’ compilation):
  - Backed (on- and off-chain assets) vs. Unbacked (algorithmic); Recourse to asset vs. No recourse to asset; Hybrid combinations exist.
- Functional considerations:
  - If price stability and large user networks are achieved, stablecoins could serve as efficient retail or cross-border payment methods and as stores of value.
  - Stablecoins can also be used as speculative financial instruments.
- Regulatory note:
  - A given stablecoin arrangement may fall under multiple regulatory regimes (money laundering, securities, banking, fund management, financial infrastructure), but tax law generally requires a single or predominant classification.

### II. VAT Treatment of Stablecoins
- VAT and money—general principles:
  - Most VAT systems do not separately tax the supply of money used as payment for goods/services by treating such supply as “out of scope” or excluded from “supply.”
  - Money-exchange transactions (currency swaps) are usually recognized as supplies but are typically VAT-exempt.
  - Distinction matters: exempt supplies reduce input tax credit entitlement and are reportable, while out-of-scope supplies typically are not.
  - Numismatic or collector money that has intrinsic value is usually taxable as a supply of goods.
- Trends and jurisprudence:
  - CJEU (Skatterverket v. David Hedqvist, Case C-264/14): exchange of traditional currencies for nontraditional “moneys” (e.g., Bitcoin) in return for a spread fee is a VAT-exempt financial transaction if (1) accepted by parties as an alternative to legal tender and (2) has no purpose other than to be a means of payment. Implication: nontraditional money may be treated as currency for VAT if those tests are met.
  - Australia (2017 GST amendment): supplies of “digital money” when used for payment are treated the same as supplies of currency (not a supply for GST). Australia’s definition excludes units that (1) are denominated in any country’s currency; (2) have value derived from something else; or (3) give entitlement to receive or direct supply of particular things unless incidental.
  - Singapore (effective January 1, 2020): digital payment tokens are treated as currency for GST; exchanging tokens for traditional currencies is GST-exempt. Proposed definition similar to Australia’s but excludes tokens that (1) give entitlement to receive or direct supply of goods/services and (2) cease to function as a medium of exchange after entitlement used. IRAS guidance: tokens pegged to or backed by fiat, baskets, commodities, or other assets should be treated as derivatives and GST-exempt financial services (IRAS 2022, paragraph 5.7).
- VAT treatment implications for stablecoins:
  - Under Australia and Singapore approaches, pegging to another asset/currency means stablecoins are treated as derivatives (exempt) rather than money (out of scope), creating substantive and compliance VAT implications.
  - Under the CJEU approach, pegging does not automatically preclude money treatment provided subjective acceptance and objective single-purpose as means of payment are satisfied.
  - Pegging to non-sovereign assets raises VAT leakage/avoidance risk because underlying commodity supplies might otherwise be taxable; low entry barriers to token issuance exacerbate this risk.
  - Policy rationales differ:
    - Australia/Singapore: restrict money classification to counter potential VAT leakage and avoidance.
    - CJEU: focus on subjective use and objective function; avoids a strict pegging prohibition but may reduce tax certainty.
- Hybridity and vouchers:
  - CJEU objective test denies money-like VAT treatment to tokens that also serve other purposes (pure payment token requirement).
  - Australia’s “incidental benefits” test is less strict—incidental nonpayment features do not preclude digital currency status.
  - Singapore’s “means of payment” test is the most permissive—token qualifies if it can be used as medium of exchange after nonpayment entitlement is used—illustrated by IRAS StoreX example where treating a multifunctional token as money can result in nontaxation of an underlying supply (file storage).

### III. Income Tax Treatment of Stablecoins
- Income tax and money—general principles:
  - A supply of money for goods/services typically does not constitute a separate income tax gain/loss when money is used as medium of exchange.
  - Numismatic or investment money used in barter is treated as property; gains/losses computed separately on disposal.
  - Transactions denominated in a currency different from the taxpayer’s functional currency give rise to foreign exchange gain/loss issues—nature (capital vs. revenue) and timing (realization vs. period-end recognition).
- Current practice and challenges for stablecoins:
  - Majority of jurisdictions effectively treat crypto assets as property even when used as means of payment (US IRS treats crypto assets as property; Australia does not treat crypto used as means of payment as (foreign) currencies for income tax; UK HMRC states current cryptoassets are not money or currency).
  - Treating stablecoins as property means each payment using a stablecoin is a realization (barter) triggering tax consequences—substantially increasing compliance burden compared with traditional currency payments.
  - Timing mismatch: income tax systems often allow end-of-period recognition for foreign exchange gains/losses, whereas property disposal rules apply per transaction—this can create different tax burdens depending on payment medium and market movements during the tax period.
- Nuanced classification considerations:
  - Fully backed, redeemable stablecoin for a single traditional currency (e.g., one token for $1) arguably functionally similar to electronic money and could be treated similarly for tax purposes if market practice supports that.
  - Unbacked algorithmic stablecoins could be argued to operate like fiat currency if their “monetary policy” is algorithmically enforced.
  - Asset-backed stablecoins (on-chain or off-chain) raise ambiguity: could be negotiable promissory notes (representative money) or proprietary interests; examples include MakerDAO collateralized debt positions (overcollateralized, margin-call dynamics).
  - Pegged-but-not-directly-backed designs (e.g., Diem reserves accessible via authorized resellers) likened to forex-based ETFs; ETF interests might be proprietary and not money.
- Administrative and international issues:
  - Subjective-use tests (treat as money if used as primary medium of exchange) present evidentiary problems and tax uncertainty; administrative solution proposed: a rebuttable presumption that stablecoins are money, with antiavoidance backstops; presumption not to apply if stablecoin is not regulated/supervised in the jurisdiction as deposit, e-money, or means of payment expressible in official monetary unit.
  - Cross-border mismatches: differing jurisdictional classifications can create double taxation or double nontaxation scenarios (examples described of country A and country B adopting differing stances).
  - Effective residence-based taxation of capital gains may require exchange of information with the issuer’s jurisdiction—problematic for decentralized stablecoins and peer-to-peer transactions without centralized intermediaries.
  - OECD’s Crypto-Asset Reporting Framework (CARF, 2022) aims to complement CRS by enabling exchange of information on crypto-asset transactions via reporting by defined crypto asset service providers; EU proposes DAC8 for crypto assets.

### IV. Conclusion — Key takeaways and policy directions
- Certainty and predictability in tax treatment are prerequisites for stablecoins to become a convenient alternative means of payment domestically and cross-border.
- Much can be achieved via clear taxpayer guidance from tax administrations; however, the multiplicity of token economic functions may necessitate nuanced or case-by-case approaches.
- To be competitive with traditional currencies, stablecoins predominantly used as means of payment require substantially similar tax treatment to currencies—VAT/GST systems show some movement in this direction, but income tax and capital gains tax treatment lag behind.
- Greater international coordination and cooperation are needed:
  - On substantive tax treatment to avoid cross-border tax arbitrage.
  - On tax administration and enforcement to equip tax authorities with tools to ensure domestic compliance (including exchange of information mechanisms).
- Greater consistency in regulatory treatment of stablecoins would help create a common reference framework to inform tax policy and administration.
- Without greater tax certainty and neutrality, stablecoins risk being unable to fulfill their promise as alternative means of payment; existing gaps and mismatches between jurisdictions may create distortions and opportunities for abuse.

*FINTECH NOTES — Taxing Stablecoins, INTERNATIONAL MONETARY FUND (excerpt).*

### References

### References

### Legal, regulatory, and supervisory reports
- Bank for International Settlements (BIS) and International Organization of Securities Commissions (IOSCO). 2021. “Application of the Principles for Financial Market Infrastructure to Stablecoin Arrangements.” Basel.
- Financial Stability Board (FSB). 2020. “Regulation, Supervision and Oversight of ‘Global Stablecoin’ Arrangements: Final Report and High-Level Recommendations.” Basel.
- Financial Stability Board (FSB). 2021. “Regulation, Supervision and Oversight of ‘Global Stablecoin’ Arrangements: Progress Report on the Implementation of the FSB High-Level Recommendations.” Basel.
- HM Treasury. 2021. “UK Regulatory Approach to Cryptoassets and Stablecoins: Consultation and Call for Evidence.” London.
- President’s Working Group on Financial Markets (PWG), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC). 2021. “Report on Stablecoins.” US Department of the Treasury, Washington, DC. home.treasury.gov/system/files/136/StableCoinReport_Nov1_508.pdf.
- US Department of the Treasury. 2021. “G20 Finance Ministers and Central Bank Governors Communiqué.” Press release, July 10.

### Taxation, VAT/GST, and administrative cooperation
- Australian Taxation Office. 2022. “Crypto Asset Investments.” Last modified June 29, 2022. www.ato.gov.au/General/Gen/Tax-treatment-of-crypto-currencies-in-Australia---specifically-bitcoin.
- Brondolo, John, and Mark Konza. 2021. “Administering the Value-Added Tax on Imported Digital Services and Low-Value Imported Goods.” IMF Technical Notes and Manuals 2021/004, International Monetary Fund, Washington DC.
- European Commission. 2022. Proposal for a Council Directive amending Directive 2011/16/EU on administrative cooperation in the field of taxation, COM(2022)707final.
- HM Revenue and Customs. 2021. Crypto Assets Manual. www.gov.uk/government/publications/tax-on-cryptoassets.
- Inland Revenue Authority of Singapore (IRAS). 2022. IRAS e-Tax Guide: GST: Digital Payment Tokens. Singapore. www.iras.gov.sg/irashome/uploadedFiles/IRASHome/e-Tax_Guides/e-Tax%20Guide_GST_Digital%20Payment%20Tokens.pdf.
- Inland Revenue (New Zealand). 2020. GST Policy Issues: An Officials’ Issues Paper. Wellington, NZ.
- Organisation for Economic Cooperation and Development (OECD). 2020. “Taxing Virtual Currencies: An Overview of Tax Treatments and Emerging Tax Policy Issues.” OECD, Paris. www.oecd.org/tax/tax-policy/taxing-virtual-currencies-an-overview-of-tax-treatments-and-emerging-tax-policy-issues.pdf.
- Organisation for Economic Co-operation and Development (OECD). 2022. “Crypto-Asset Reporting Framework and Amendments to the Common Reporting Standard.” OECD, Paris. www.oecd.org/tax/exchange-of-tax-information/crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard.pdf.
- PricewaterhouseCoopers (PwC). 2020. “Annual Global Crypto Tax Report 2020.”
- US Internal Revenue Service. 2014. IRS Virtual Currency Guidance. www.irs.gov/pub/irs-drop/n-14-21.pdf.

### IMF and macro-financial/statistical guidance
- International Monetary Fund (IMF). 2019. “Treatment of Crypto Assets in Macroeconomic Statistics.” International Monetary Fund, Washington, DC.
- International Monetary Fund (IMF). 2020. “Digital Money Across Borders: Macro-Financial Implications.” IMF Policy Paper No. 2020/050, Washington, DC.
- International Monetary Fund (IMF). 2021. Global Financial Stability Report: COVID-19, Crypto, and Climate: Navigating Challenging Transitions. Washington, DC, October.

### Legal, commercial law, and sector taxation analysis
- Cheng, Jess. 2020. “How to Build a Stablecoin: Certainty, Finality, and Stability Through Commercial Law Principles.” Berkley Business Law Journal 17 (2): 320.
- Schenk, Alan, and Howell Zee. 2004. “Financial Services and the Value-Added Tax.” In Taxing the Financial Sector, edited by Howell Zee. Washington, DC: International Monetary Fund.
- Waerzeggers, Christophe, and Irving Aw. 2019. “Difficulties in Achieving Neutrality and other Challenges in Taxing Cryptoassets.” In Cryptoassets: Legal, Regulatory and Monetary Perspectives, edited by Chris Brummer. New York: Oxford University Press.

### Crypto-asset regulation, AML/CFT, and fintech notes
- Cuervo, Cristina, Anastasiia Morozova, and Nobuyasu Sugimoto. 2019. “Regulation of Crypto Assets.” IMF Fintech Note 19/03, International Monetary Fund, Washington, DC.
- Schwarz, Nadine, Kristel Poh, Ke Chen, Grace Jackson, Kathleen Kao, Francisca Fernando, and Maksym Markevych. 2021. “Virtual Assets and Anti-Money Laundering and Combating the Financing of Terrorism.” IMF Fintech Note 21/03, International Monetary Fund, Washington, DC.

*Fintech Notes: Taxing Stablecoins  NOTE/2023/002*

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_Source: https://www.imf.org/-/media/files/publications/ftn063/2023/english/ftnea2023002.pdf_