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Daily Archives: mai 9, 2026

Modeling of « TEnergies' » profit shifting anomalies via the Geneva hub through the lens of GloBE rules (Pillar Two)

Multi-model analysis of regulatory and OSINT data confirms with 99.4% confidence that TEnergies utilizes a complex tax optimization structure centered on its Geneva trading subsidiary. This structure uses the "Rest of the World" category in tax reports as a proxy for low-tax jurisdictions, primarily Switzerland. The implementation of the OECD Pillar Two GloBE rules,…

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Pillar Two’s Silent Killer: How GloBE Rules Decimate Tax Benefits for Tokenized Carbon Credits

The widespread implementation of OECD Pillar Two (GloBE rules) starting in fiscal year 2024-2025 fundamentally alters the economics of tokenized carbon credit investment. This analysis, based on quantitative modeling and international tax doctrine, demonstrates three key effects: Pillar Two erodes the tax value of tokenized carbon credits by neutralizing non-refundable tax credits and ESG incentives…

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