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ATO Australian tax treatment for options trades 🇦🇺

I am posting this as I hope it will help other Australian options traders trading in US options with their tax treatment for ATO (Australian Tax Office) purposes. The ATO provides very little guidance on tax treatment for options trading and I had to do a lot of digging to get to this point. I welcome any feedback on this post.

The Deloitte Report from 2011

My initial research led me to this comprehensive Deloitte report from 2011 which is hosted on the ASX website. I've been through this document about 20 times and although it's a great report to understand how different scenarios apply, it's still really hard to find out what's changed since 2011.
I am mainly relating myself to the scenario of being an individual and non-sole trader (no business set up) for my trading. I think this will apply to many others here too. According to that document, there isn't much guidance on what happens when you're an options premium seller and close positions before they expire.
Note that the ATO sometimes uses the term "ETO" (Exchange Traded Option) to discuss what we're talking about here with options trading.
Also note: The ATO discusses the separate Capital Gains Tax ("CGT") events that occur in each scenario in some of their documents. A CGT event will then determine what tax treatment gets applied if you don't know much about capital gains in Australia.

ATO Request for Advice

Since the Deloitte report didn't answer my questions, I eventually ended up contacting the ATO with a request for advice and tried to explain my scenario: I'm an Australian resident for tax purposes, I'm trading with tastyworks in $USD, I'm primarily a premium seller and I don't have it set up with any business/company/trust etc. In effect, I have a rough idea that I'm looking at capital gains tax but I wanted to fully understand how it worked.
Initially the ATO respondent didn't understand what I was talking about when I said that I was selling a position first and buying it to close. According to the laws, there is no example of this given anywhere because it is always assumed in ATO examples that you buy a position and sell it. Why? I have no idea.
I sent a follow up request with even more detail to the ATO. I think (hope) they understood what I meant now after explaining what an options premium seller is!

Currency Gains/Losses

First, I have to consider translating my $USD to Australian dollars. How do we treat that?
FX Translation
If the premium from selling the options contract is received in $USD, do I convert it to $AUD on that day it is received?
ATO response:
Subsection 960-50(6), Item 5 of the Income Tax Assessment Act 1997 (ITAA 1997) states the amount should be translated at the time of the transaction or event for the purposes of the Capital Gains Tax provisions. For the purpose of granting an option to an entity, the time of the event is when you grant the option (subsection 104-20(2) ITAA 1997).
This is a very detailed response which even refers to the level of which section in the law it is coming from. I now know that I need to translate my trades from $USD to $AUD according to the RBA's translation rates for every single trade.
But what about gains or losses on translation?
There is one major rule that overrides FX gains and losses after digging deeper. The ATO has a "$250k balance election". This will probably apply to a lot of people trading in balances below $250k a lot of the FX rules don't apply. It states:
However, the $250,000 balance election broadly enables you to disregard certain foreign currency gains and losses on certain foreign currency denominated bank accounts and credit card accounts (called qualifying forex accounts) with balances below a specified limit.
Therefore, I'm all good disregarding FX gains and losses! I just need to ensure I translate my trades on the day they occurred. It's a bit of extra admin to do unfortunately, but it is what it is.

Credit Trades

This is the scenario where we SELL a position first, collect premium, and close the position by making an opposite BUY order. Selling a naked PUT, for example.
What happens when you open the position? ATO Response:
The option is grantedCGT event D2 happens when a taxpayer grants an option. The time of the event is when the option is granted. The capital gain or loss arising is the difference between the capital proceeds and the expenditure incurred to grant the option.
This seems straight forward. We collect premium and record a capital gain.
What happens when you close the position? ATO Response:
Closing out an optionThe establishment of an ETO contract is referred to as opening a position (ASX Explanatory Booklet 'Understanding Options Trading'). A person who writes (sells) a call or put option may close out their position by taking (buying) an identical call or put option in the same series. This is referred to as the close-out of an option or the closing-out of an opening position.
CGT event C2 happens when a taxpayer's ownership of an intangible CGT asset ends. Paragraph 104-25(1)(a) of the ITAA 1997 provides that ownership of an intangible CGT asset ends by cancellation, surrender, or release or similar means.
CGT event C2 therefore happens to a taxpayer when their position under an ETO is closed out where the close-out results in the cancellation, release or discharge of the ETO.
Under subsection 104-25(3) of the ITAA 1997 you make a capital gain from CGT event C2 if the capital proceeds from the ending are more than the assets cost base. You make a capital loss if those capital proceeds are less than the assets reduced cost base.
Both CGT events (being D2 upon granting the option and C2 upon adopting the close out position) must be accounted for if applicable to a situation.
My take on this is that the BUY position that cancels out your SELL position will most often simply realise a capital loss (the entire portion of your BUY position). In effect, it 'cancels out' your original premium sold, but it's not recorded that way, it's recorded as two separate CGT events - your capital gain from CGT event D2 (SELL position), then, your capital loss from CGT event C2 (BUY position) is also recorded. In effect, they net each other out, but you don't record them as a 'netted out' number - you record them separately.
From what I understand, if you were trading as a sole tradecompany then you would record them as a netted out capital gain or loss, because the trades would be classified as trading stock but not in our case here as an individual person trading options. The example I've written below should hopefully make that clearer.
EXAMPLE:
Trade on 1 July 2020: Open position
Trade on 15 July 2020: Close position
We can see from this simple example that even though you made a gain on those trades, you still have to record the transactions separately, as first a gain, then as a loss. Note that it is not just a matter of netting off the value of the net profit collected and converting the profit to $AUD because the exchange rate will be different on the date of the opening trade and on the date of the closing trade we have to record them separately.

What if you don't close the position and the options are exercised? ATO Response:
The option is granted and then the option is exercisedUnder subsection 104-40(5) of the Income Tax Assessment Act 1997 (ITAA 1997) the capital gain or loss from the CGT event D2 is disregarded if the option is exercised. Subsection 134-1(1), item 1, of the ITAA 1997 refers to the consequences for the grantor of the exercise of the option.
Where the option binds the grantor to dispose of a CGT asset section 116-65 of the ITAA 1997 applies to the transaction.
Subsection 116-65(2) of the ITAA 1997 provides that the capital proceeds from the grant or disposal of the shares (CGT asset) include any payment received for granting the option. The disposal of the shares is a CGT event A1 which occurs under subsection 104-10(3) of the ITAA 1997 when the contract for disposal is entered into.
You would still make a capital gain at the happening of the CGT event D2 in the year the event occurs (the time the option is granted). That capital gain is disregarded when the option is exercised. Where the option is exercised in the subsequent tax year, the CGT event D2 gain is disregarded at that point. An amendment may be necessary to remove the gain previously included in taxable income for the year in which the CGT event D2 occurred.
This scenario is pretty unlikely - for me personally I never hold positions to expiration, but it is nice to know what happens with the tax treatment if it ultimately does come to that.

Debit Trades

What about the scenario when you want to BUY some options first, then SELL that position and close it later? Buying a CALL, for example. This case is what the ATO originally thought my request was about before I clarified with them. They stated:
When you buy an ETO, you acquire an asset (the ETO) for the amount paid for it (that is, the premium) plus any additional costs such as brokerage fees and the Australian Clearing House (ACH) fee. These costs together form the cost base of the ETO (section 109-5 of the ITAA 1997). On the close out of the position, you make a capital gain or loss equal to the difference between the cost base of the ETO and the amount received on its expiry or termination (subsection 104-25(3) of the ITAA 1997). The capital gain or loss is calculated on each parcel of options.
So it seems it is far easier to record debit trades for tax purposes. It is easier for the tax office to see that you open a position by buying it, and close it by selling it. And in that case you net off the total after selling it. This is very similar to a trading shares and the CGT treatment is in effect very similar (the main difference is that it is not coming under CGT event A1 because there is no asset to dispose of, like in a shares or property trade).

Other ATO Info (FYI)

The ATO also referred me to the following documents. They relate to some 'decisions' that they made from super funds but the same principles apply to individuals they said.
The ATO’s Interpretative Decision in relation to the tax treatment of premiums payable and receivable for exchange traded options can be found on the links below. Please note that the interpretative decisions below are in relation to self-managed superannuation funds but the same principles would apply in your situation [as an individual taxpayer, not as a super fund].
Premiums Receivable: ATO ID 2009/110

Some tips

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Yen, Swiss franc benefit as dollar falls on U.S.-China conflict and economic fears

This is the best tl;dr I could make, original reduced by 62%. (I'm a bot)
London - The dollar fell on Monday, after reaching its lowest since September 2018 overnight, as deteriorating U.S.-China relations and concerns about the U.S. economy saw investors look to the yen and Swiss franc as safe havens.
With domestic economic concerns trumping its role as a safe-haven currency, the dollar index fell overnight, steadied in the early hours of the morning, then continued its descent.
At 1058 GMT, the dollar index was at 93.777, down 0.6% on the day =USD. As COVID-19 infections show no signs of slowing in the U.S., investors are doubtful of a quick economic recovery.
With the dollar's role as safe haven in question, the Japanese yen and Swiss franc strengthened, suggesting that investors are seeking safety elsewhere.
Versus the dollar, the Swiss franc reached a five-year high of 0.9167 overnight CHF=EBS. The dollar lost 0.8% against the yen, which strengthened to a four-month high of 105.265 JPY=EBS. "Under a general dollar sell-off environment the yen is benefiting as a safe-haven currency," said Neil Jones, head of FX sales at Mizuho, adding that month-end flows were also playing a role.
"Markets are potentially looking for risk aversion currencies, and this seems to be a discretionary switch away from dollar into the yen and the Swiss franc," he said.
Summary Source | FAQ | Feedback | Top keywords: dollar#1 yen#2 Swiss#3 franc#4 USD#5
Post found in /Economics.
NOTICE: This thread is for discussing the submission topic. Please do not discuss the concept of the autotldr bot here.
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In swaps we trust? Disappearing dollars drive currency trading dependence - Reuters

This is the best tl;dr I could make, original reduced by 83%. (I'm a bot)
LONDON - As dollars dry up, global finance is growing increasingly dependent on opaque currency trading to keep cash flowing.
Swaps users had a scare in September, when the U.S. Federal Reserve had to pump cash into markets as rates in the $2.2 trillion U.S. "Repo" market spiked and spilled into FX swap markets, sending the premium to borrow dollars shooting higher.
Reflecting the increased reliance on currency markets to borrow dollars, FX swap volumes have grown to represent 49% of total currency trading, from 42% in 2013, Bank for International Settlements figures from August show.
OFF-BALANCE SHEET. Unlike regular 'spot' currency transactions, swaps involve two parties swapping one currency for another.
Many central bankers say bank borrowing and funding via swaps, which are typically used for hedging, day-to-day liquidity management or even speculation, is driving the increase in FX swaps as they are "Off-balance sheet".
The central bank official said stress tests implied some banks use swaps for more than 10% of their funding, while the BIS says dollars are on one side of 90% of all currency trades.
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Rich or Right, It's Your Decision (Part 2)

The first danger of any Forex trading software, especially fully automated systems, Forex Millennium Review is that the risk settings are too high to begin with. Many developers are designing their systems with astronomical risk levels, often risking 5-10% of capital on a trade... and sometimes even more! That's crazy, and it's no wonder that people end up blowing up their accounts and wondering why. Additionally, you should check that your leverage levels in the Forex brokerage account match up to the recommended system parameters, otherwise that's another time bomb waiting to explode.

Another hidden danger that's not so obvious in the short term is your own mental and emotional factors. While people often say that using automatic systems is a good way to eliminate emotional trading, it's inevitable that your emotions will still get involved. For example, traders often get "cold feet" after a few large losses, and start second guessing their trading program or even abandoning it entirely. Or, they get too excited when the big wins start piling up, start getting overconfident and doubling/tripling their risk.

only for the market to turn and destroy all their gains and then some. Whatever the manifestation of emotions in trading, it's clear that you need to manage it just as much when you're using Forex trading software as with any other form of trading. In the past, the only people who get to trade in the FX market are corporations, banks, and the like; because of the Internet, however, individuals can now become traders and get the chance to profit from Forex. Any person aspiring to become a Foreign Exchange trader, of course, should be taught FX trading basics, and of course, trading currency strategies he or she can apply to increase the chances of winning in his or her trades.

Some people may be wondering what things are traded in Forex. The answer: the only things you trade are the currencies, specifically currency pairs. The most popular pairs include: USD/CAD (the US dollar and the Canadian dollar), AUD/USD (the Aussie dollar and the US dollar), EUUSD (the Euro and the US Dollar), and so forth. The first currency you see in the pair is the so called base currency, while the second one is the quote currency.

https://binaryforexwizard.com/forex-millennium-review/
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New Beginner info / FAQ section for futures

I feel like with all the cheating and drama going on with spot fx we should at the very least have a dedicated section on the right for guidance on futures contracts.
The shady Cypriot brokers and ones on other random islands are lying and selling a dream so let's take a look at the reality of spot fx...
Currency markets are the most liquid and active markets of any sector. However, there is also a great deal of misinformation, slick advertising, and even outright deception regarding this $2 Trillion Dollar a Day marketplace. For starters, a large percentage of that $2 Trillion is traded through what is referred to as the interbank market. The interbank market is the top-level foreign exchange market where banks exchange different currencies. This trading between banks is not accessible to retail traders and is estimated to account for the vast majority of the Trillion Dollar liquidity factor that attracts so many retail traders in the first place.
Here are a few of the reasons to trade futures:
-Level playing field for all participants
-Deep liquidity on major currency contracts
-Safety and security of central clearing
If your Forex brokerage firm uses a dealing desk, your buy and sell orders never actually reach the true Forex market. In other words, you do not have access to the inter-bank market. Instead you are buying and selling at prices set, and potentially manipulated by the dealing desk. This is known as conflict of interest.
The Chicago Mercantile Exchange guarantees each transaction. Futures contracts are legally binding! This means that if you go long a currency futures contract and your speculation was correct, you will walk away from the trade with your profit even if the person that took the other side of the trade fails to pay. This is what we call counterparty risk.
Take a moment, have a break and take a look at all the horror stories on forex factory, for instance.
Whether you are a large institution or an individual trader, everyone is on equal footing when it comes to pricing currency futures. EVERYBODY gets the same price regardless of who you are (individual or mega bank). Best price wins, it is as simple as that — something that is not always the case in the fragmented OTC FX market. The spreads are also very tight if you trade liquid future contracts.
Spot fx brokers also control their price feeds. They can widen the spreads as they see fit and they can really screw you over if they want to. Believe me when I say that most fx brokers don't want you to win! Even the ones that claim to have liquidity providers... Those are nothing but price feeds. Quotes. Nothing more....
And Forex firms offering a "fixed" 3-5 point spread may not be charging traders commission outright, or even in a form that shows up on an account statement, but there are significant costs built into the synthetic market that they provide to you.
No middle man, no market maker. Yes, Forex is an electronic market, but your order still ends up on a "dealing desk" where a human handles your order. Or an algorithm... Basically, a Market Maker. He could make you or break you. With E-mini Futures you have a level playing field. You trade on a centralised and CFTC regulated exchange. Whether you're Goldman Sachs or Joe from Idaho, you get equal treatment!
If you're worried about Liquidity - 1.5-3m contracts trade hands everyday on the S&P 500 E-mini Futures Contract. If you want in or out of a position, there is almost always someone waiting and willing to take the other side of your trade (24/5) just 1 tick away. This simply isn't true for all Forex Pairs.
Low Cost of Doing Business - Commissions on a self directed SP500 E-mini Trade (ES) should be no more than $3.00 per side or $6.00 per round turn. While many Forex Brokers tout "Zero Commission", we all know there's no free lunch. Forex Brokers don't need to charge a commission because they make money off of the bid/ask spread "they create" and then take the other side of your trade. Run the numbers... for every $100 in profits or loss, you will spend a larger % in "cost of doing business" in the Forex Market than you will in the S&P E-mini Market. Don't take my word for it... go take some real trades and you'll quickly see the truth.
Zero Interest - If you you trade the ES intraday, expect to put up $500 per contract as a "bond" for lack of a better term. That's it. No hidden cost. Forex however, has a "cost of carry" associated which means interest may be charged or paid on positions taken.
Fiduciary Responsibility - Even regulated US Forex firms are not required to segregate customer funds. If a regulated firm goes under, you do not have the protection of the CFTC and the NFA as you do in the Futures Markets.
Turn ON The Volume Please - In Forex, since there is no centralised exchange, it is impossible to get a true read on volume. Not so with the S&P 500 "ES" E-mini. Simply turn on the volume indicator and you have exact numbers for Volume Analysis. GS and CITI have huge research departments with hundreds of employees, but they know nothing about volume that you don't know via a free indicator on your direct access trading platform. Just one more example of the level playing field we constantly speak of.
Centralised Clearing - All trades are cleared via the CME - Chicago Mercantile Exchange. All trades, including time and sales, are public information and posted in real time.
Edit: By the way, if you're worried about discrepancies, currency futures charts look almost exactly the same as their spot fx siblings! So you can easily apply your current strategy to this market, too!
A great example would be "M6E" vs "EUUSD"
SO GUYS, LET'S ACCEPT REALITY AND LET'S DO SOMETHING ABOUT IT. DO YOU AGREE?
Source: cfrn.net
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Barclays, Citigroup, JP Morgan, MUFG and Royal Bank of Scotland were fined a combined $1.2 billion by the European Union on Thursday for rigging the multi-trillion dollar foreign exchange market.

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BRUSSELS/LONDON - Barclays, Citigroup, JP Morgan, MUFG and Royal Bank of Scotland were fined a combined 1.07 billion euros by the European Union on Thursday for rigging the multi-trillion dollar foreign exchange market.
The EU competition enforcer said most of the traders knew each other on a personal basis and set up chatrooms such as "Essex Express 'n the Jimmy", which was given this name because all of them except "James" lived in Essex, to the east of London, and met on their train commute to the British capital.
The five-year investigation found nine traders spread across the banks exchanged sensitive information and trading plans in the chatrooms and occasionally co-ordinated trading strategies.
Occasionally the traders would co-ordinate trading activity, for example through a practice called 'standing down' whereby some of the group would temporarily stop trading to avoid interfering with others, the commission said.
BANANA SPLIT. The "Three Way Banana Split" cartel, made up of traders at UBS, Barclays, RBS, Citigroup and JP Morgan, was handed a fine totaling 811.2 million euros.
U.S. prosecutors have charged a handful of former traders over forex rigging.
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Euro posts biggest drop in four weeks as Italian yields spike

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"The Italian situation is an excuse for some investors who had been expecting a rebound in the last few weeks of the year as recent data out of Europe has hardly been supportive," State Street Global Markets head of macro strategy Timothy Graf said.
BIGGER MARGIN. Struggling European economic data, particularly on the inflation front, has stood in sharp contrast with data out of the U.S. in recent weeks, prompting hedge funds to whittle down their long positions on the euro to their lowest for nearly 1-1/2 years.
"The dollar has been supported by some strong data but with the market already long dollars at these levels, new data has to surprise investors by a bigger margin to push it higher," Credit Agricole FX strategist Manuel Oliveri said.
The dollar climbed half a percent last week, marking its second consecutive week of gains as hedge funds ramped up their dollar holdings by $3.4 billion to $28.7 billion, the largest rise since end-December 2016, according to latest data.
A sudden and steep rise in Treasury yields had underpinned the dollar for much of last week.
The big focus for dollar bulls this week will be the release of U.S. CPI data on Thursday.
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Britain has extended its lead in the global currency trading business in the two years since it voted to leave the European Union, in another sign London is likely to continue to be one of the world’s top two financial centers even after Brexit.

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LONDON - Britain has extended its lead in the global currency trading business in the two years since it voted to leave the European Union, in another sign London is likely to continue to be one of the world's top two financial centers even after Brexit.
Reuters' analysis, based on surveys released by central banks in the five biggest trading centers, shows forex trading volumes in Britain had grown by 23 percent to a record daily average of $2.7 trillion in April compared to April 2016.
"The luck of geography has helped because most of the big market moving news, whether in the U.S. or Europe, has occurred during London's trading hours," said Neil Jones, London-based head of hedge fund sales at Japan's Mizuho Bank.
These products, the largest part of Britain's currency market, are sold to customers around the world, not just the EU. Banks in Britain, including the London operations of global players, are moving some staff to European cities on expectations that they will the lose the automatic right to sell services to EU investors after Brexit.
The city's tightening grip on forex trade does not prove London won't suffer from Brexit, but it does underscore the attractiveness for banks of maintaining large international operations in the city, industry experts said.
"The FX market is effectively an offshore dollar market and offshore dollars are always going to be looking for an international home, and that's London."
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U.S. tax repatriation plan may not cure long-term dollar weakness

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NEW YORK - Investors looking for the U.S. Republican tax bill to prompt multinational companies to convert foreign profits into dollars and end the worst slide in the greenback in a decade may have to temper their hopes for a prolonged rebound.
The bill President George W. Bush signed in October 2004 drastically reduced tax rates to 5.25 percent over a 12-month window and, along with aggressive tightening by the Federal Reserve, helped send the dollar nearly 13 percent higher the following year.
DOLLAR BULLISHNESS. Prospects of a tax break on companies' foreign earnings and expectations of wider U.S. budget deficits helped boost the dollar to its highest levels since 2002 soon after Trump's presidential victory in November 2016.
"Even a significant wave of repatriation might not lift the dollar directly, as some of the largest U.S. corporations already hold a lot of cash in dollar-denominated assets," said Shaun Osborne, chief FX strategist at Scotiabank in Toronto.
Despite some skepticism about U.S. repatriation flows, some analysts say the dollar could get a short-term boost.
He does not expect a dollar rally to continue beyond the second quarter of 2018, partly due to concerns about the tax plan's impact on the U.S. fiscal deficit.
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U.S. dollar index hits 15-month low on Fed, political uncertainty

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NEW YORK - The U.S. dollar briefly touched a 15-month low against a basket of major currencies on Tuesday on political turmoil in Washington and weak U.S. economic data that kept the Federal Reserve's policy outlook uncertain.
While the dollar was last higher on the day as investors consolidated positions, it was not far from its lowest in more than a year against major rivals as uncertainty was expected to continue weighing on the greenback following President Donald Trump's ouster of White House communications chief Anthony Scaramucci on Monday.
The dollar index, which measures the greenback against a basket of six major rivals, was last up 0.2 percent at 93.065 after touching 92.777, the lowest since early May 2016.
The dollar fell below 110 yen for the first time in more than six weeks, touching 109.94 yen JPY=.
The dollar index fell in July, its fifth consecutive monthly decline, the longest such stretch since December 2010 through April 2011.
"(Political) policy uncertainty in the U.S. I think has been the biggest driver of declines in the dollar recently," said Sireen Harajli, FX strategist at Mizuho in New York.
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Dollar steady near 13-month lows

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LONDON - The dollar held near a 13-month low against a basket of currencies on Monday, weighed down by political uncertainty and increased short positions, but markets were wary of pushing it lower before data due later this week.
Broad market positioning data for the week of July 25 showed short bets against the dollar swollen to their highest levels since a "Taper-tantrum" peak in early 2013.
"Our short-term positions indicators are flashing red in terms of extreme bets against the dollar, especially against the euro and the Aussie and in this kind of environment, a small negative surprise in data elsewhere can trigger a washout," said Viraj Patel, an FX strategist at ING in London.
With euro zone inflation data on Monday seen well below European Central Bank estimates, a risk for a pull-back is rising.
Central bank policy decisions are also due from Australia and the United Kingdom this week with U.S. jobs data scheduled on Friday.
Sterling has been buoyant against the broadly weaker dollar, supported by hopes that Britain will exit the European Union under a transitional deal.
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