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By decision of 18 December 2002, the German Supreme Tax Court held that the option premium received by the writer of an option (call or put) should be recorded as a liability in his books and only taken to income when realised. Under the date of January 12, 2004 the Ministry of Finance issued a decree recognising the Supreme Tax Court decision in principle but disallowing a tax deduction for risks from the option transaction exceeding the amount of the option premium. This article discusses the