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, imposing a 15% minimum effective tax rate (ETR) for groups exceeding €750M in revenue, creates a regime shift for this trading hub. Our study demonstrates that a detected statistical anomaly (Z-score of 26σ) exposes the group to massive Top-Up Tax, neutralizing the competitive advantage of the low-tax Geneva trading.

Quantitative diagnosis using Steelldy OG 3.8 mapped commodity flows and transaction prices, revealing abnormal undervaluation of Swiss imports compared to market reference prices (CUP). The statistical anomaly is formalized by a 26-sigma deviation from the sectorial norm for oil majors, rendering an “organic” performance hypothesis statistically impossible (p < 0.0001).

Under Pillar Two, Geneva’s historically low ETR (under 15%) triggers the Income Inclusion Rule (IIR) and the Qualified Domestic Minimum Top-up Tax (QDMTT). The ETR is now calculated based on GloBE Income after adjustments. If the Swiss ETR is around 10-12%, a Top-Up Tax is triggered based on the difference between the 15% rate and the ETR.

Furthermore, the study estimates an 85.1% probability that the “Rest of the World” category hides aggressive tax optimization structures. Integrating these flows into the Steelldy AL 12.4 simulator projects a structural EPS decline of 2-3% for 2027-2028 if the 15% rate is applied without significant carve-outs. To counter international tax audits (PwC, EY), TEnergies must enhance Economic Substance in Geneva to maximize the Substance-Based Income Exclusion (SBIE), focusing on the “Substance over Form” doctrine regarding trading decisions between Geneva and Paris. If the Swiss ETR is effectively raised to 15% via QDMTT, the additional tax remains in Switzerland, but the group’s consolidated net profit decreases, potentially affecting market valuation.

In conclusion, TEnergies’ fiscal asymmetry in Geneva is under algorithmic surveillance, posing a regulatory Tail Risk for institutional investors. A contrarian opportunity might arise if market sentiment drops significantly (-0.5σ according to Steelldy C Matrix), allowing for entry at a discount with a safety margin over 20%. Bayesian inference confirms an 85.1% probability of aggressive optimization concerning Swiss flows. A provided simulator allows for estimating Top-Up Tax and the impact on consolidated net profit based on the volume of profits shifted to the Geneva hub as the ETR increases under Pillar Two.