Traditional accounting practices exclude foreign exchange derivatives used to hedge international trade and foreign currency bonds, the BIS argues. Reuters
Traditional accounting practices exclude foreign exchange derivatives used to hedge international trade and foreign currency bonds, the BIS argues. Reuters
Traditional accounting practices exclude foreign exchange derivatives used to hedge international trade and foreign currency bonds, the BIS argues. Reuters
Traditional accounting practices exclude foreign exchange derivatives used to hedge international trade and foreign currency bonds, the BIS argues. Reuters

Global debt may be understated by $13 trillion


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Global debt may be under-reported by around US$13 trillion because traditional accounting practices exclude foreign exchange derivatives used to hedge international trade and foreign currency bonds, the BIS said on Sunday.

Bank for International Settlements researchers said it was hard to assess the risk this "missing" debt poses, but that the main worry was a liquidity crunch like the one that seized FX swap and forwards markets during the financial crisis.

The $13tn unaccounted-for exposure exceeds the on-balance-sheet debt of $10.7tn that data shows was owed by firms and governments outside the United States at end-March.

The fact these FX derivatives do not appear on financial and non-financial institutions' balance sheets under current accounting rules means little is known about where the debt lies.

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"The debt remains obscured from view," Claudio Borio, head of the BIS's monetary and economic department, and two colleagues, Robert McCauley and Patrick McGuire, said in its latest quarterly report.

"Accounting conventions leave it mostly off-balance sheet, as a derivative, even though it is in effect a secured loan with principal to be repaid in full at maturity," BIS said.

Explaining the risk they added: "In particular, the short maturity of most FX swaps and forwards can create big maturity mismatches and hence generate large liquidity demands, especially during times of stress."

When buying a foreign asset, a domestic investor has three choices: buy a currency forward, undertake an FX swap or do a repurchase transaction.

But while the first two are recorded on balance sheets on a net basis without taking the notional amount into consideration, a repo transaction is recorded on a gross basis, when all these three types of trades are essentially similar - secured debt.

All these trades are used to remove the foreign exchange risk in a purchase of foreign securities.

In a swap, two parties exchange currencies and agree to reverse the swap later. In a forward contract the parties agree to exchange currencies at a fixed date and price in the future.

Swaps and forwards amounted to more than $3tn a day last year, equivalent to more than 60 per cent of total FX turnover, the BIS said. More than 90 per cent of the market was in dollars and FX swaps accounted for 75 per cent of the total.

They are also overwhelmingly short-term. Three-quarters of positions had a maturity of less than a year at the end of 2016.

Though the outstanding amount of FX swaps and forward contracts has quadrupled since the early 2000s to $58tn - almost three times the $21tn value of world trade - it dropped after the financial crisis, reflecting a drop in hedging needs as both trade and investments collapsed.

The BIS said non-financial users employ FX forwards and currency swaps for speculation and to hedge international trade and foreign currency bonds.

Institutional investors, asset managers and hedge funds used forwards to hedge their holdings and take positions while financial firms used swaps to hedge international bonds.

While this debt is mostly secured as counterparties usually enter into forward transactions to reduce currency exposure, the make-up of these largely short-term transactions means they are often the most vulnerable to strains in the financial system.

For example, European banks increased their reliance on these money market instruments during the global financial crisis to secure their dollar funding while the collapse of the structured products markets during the crisis sent shockwaves rippling through the system.

"Markets calmed only after coordinated central bank swap lines to supply dollars to non-U.S. banks became unlimited in October 2008," the BIS report said.

As for who is lending the dollars to non-US banks, the BIS said the funding came from US banks, central banks European agencies, supranational organisations and private non-banks.

"All of these appear to provide some funding, with US banks and central banks together closing about half the gap," it said.

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UPI facts

More than 2.2 million Indian tourists arrived in UAE in 2023
More than 3.5 million Indians reside in UAE
Indian tourists can make purchases in UAE using rupee accounts in India through QR-code-based UPI real-time payment systems
Indian residents in UAE can use their non-resident NRO and NRE accounts held in Indian banks linked to a UAE mobile number for UPI transactions

Ten tax points to be aware of in 2026

1. Domestic VAT refund amendments: request your refund within five years

If a business does not apply for the refund on time, they lose their credit.

2. E-invoicing in the UAE

Businesses should continue preparing for the implementation of e-invoicing in the UAE, with 2026 a preparation and transition period ahead of phased mandatory adoption. 

3. More tax audits

Tax authorities are increasingly using data already available across multiple filings to identify audit risks. 

4. More beneficial VAT and excise tax penalty regime

Tax disputes are expected to become more frequent and more structured, with clearer administrative objection and appeal processes. The UAE has adopted a new penalty regime for VAT and excise disputes, which now mirrors the penalty regime for corporate tax.

5. Greater emphasis on statutory audit

There is a greater need for the accuracy of financial statements. The International Financial Reporting Standards standards need to be strictly adhered to and, as a result, the quality of the audits will need to increase.

6. Further transfer pricing enforcement

Transfer pricing enforcement, which refers to the practice of establishing prices for internal transactions between related entities, is expected to broaden in scope. The UAE will shortly open the possibility to negotiate advance pricing agreements, or essentially rulings for transfer pricing purposes. 

7. Limited time periods for audits

Recent amendments also introduce a default five-year limitation period for tax audits and assessments, subject to specific statutory exceptions. While the standard audit and assessment period is five years, this may be extended to up to 15 years in cases involving fraud or tax evasion. 

8. Pillar 2 implementation 

Many multinational groups will begin to feel the practical effect of the Domestic Minimum Top-Up Tax (DMTT), the UAE's implementation of the OECD’s global minimum tax under Pillar 2. While the rules apply for financial years starting on or after January 1, 2025, it is 2026 that marks the transition to an operational phase.

9. Reduced compliance obligations for imported goods and services

Businesses that apply the reverse-charge mechanism for VAT purposes in the UAE may benefit from reduced compliance obligations. 

10. Substance and CbC reporting focus

Tax authorities are expected to continue strengthening the enforcement of economic substance and Country-by-Country (CbC) reporting frameworks. In the UAE, these regimes are increasingly being used as risk-assessment tools, providing tax authorities with a comprehensive view of multinational groups’ global footprints and enabling them to assess whether profits are aligned with real economic activity. 

Contributed by Thomas Vanhee and Hend Rashwan, Aurifer

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