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Specific Implications for Intangible Assets : Regulatory Fundamentals and Architecture of Pillar Two in France

1.1 Exclusion of Tokenized Carbon Credits from the Substance-Based Carve-Out (SBCO) The Substance-Based Carve-Out (SBCO), also referred to as the Substance-Based Income Exclusion (SBIE), is one of Pillar Two's key mechanisms for preserving the attractiveness of productive investments. It allows a portion of the GloBE income subject to tax to be excluded from the calculation,…

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