Comparative Analysis and Mapping of Tax Risks

1.1 Tripartite Classification Framework for Carbon Credit Tokens

The taxonomy of Carbon Credit Tokens (CCTs) proposed by STEELLDY is structured around three fundamental categories, each presenting a distinct tax risk profile under the Pillar Two framework. This tripartite classification | direct possession tokens, pool tokens, and synthetic tokens | constitutes an essential analytical framework for assessing the tax exposure of tokenized environmental asset portfolios. The relevance of this taxonomy goes beyond mere descriptive categorization; it directly conditions the calculation of the effective tax rate, the determination of the top-up tax base, and the selection of tax optimization strategies suited to each token type.

Direct possession tokens represent a digital claim on a physical carbon credit held in custody by an approved custodian, with a one-to-one correspondence between the token and the underlying credit unit identifiable by its serial number in a recognized registry (Verra VCS, Gold Standard, Climate Action Reserve). Pool tokens represent an interest in a collective portfolio of carbon credits with heterogeneous characteristics, structured as a common fund or a collective investment entity. Synthetic tokens provide exposure to carbon credit prices without physical holding, through derivative mechanisms such as futures contracts, total return swaps, or price oracles replicating a benchmark index.