Calculation of the Effective Tax Rate under Pillar Two

1.1 Formal Specification of the GloBE ETR The determination of the Effective Tax Rate (ETR) under the GloBE regime follows a formal specification whose mathematical precision conditions the entire tax calculation chain. The ETR per jurisdiction, denoted ETR_j for jurisdiction j, is defined by the ratio: ETR_j = ACT_j / GI_j, where ACT_j represents the…

07/06/20260Comments

ByOleg Turceac

The GloBE Regime and Its Structural Implications for Tokenized Assets

Genesis and Legal Foundations of Pillar Two in the OECD/G20 Framework Pillar Two, the product of the OECD/G20 work on base erosion and profit shifting (BEPS 2.0), constitutes the most ambitious reform of international taxation since the OECD and UN model conventions. Its stated objective is to establish a minimum effective tax rate of 15%…

07/02/20260Comments

ByOleg Turceac

Taxonomy and Characterization of Carbon Credit Tokens (CCTs)

1.1 Direct Ownership Tokens 1.1.1 On-chain Representation of Carbon Credits Held in Custody by the Investor Direct ownership tokens constitute the most fundamental form of carbon credit tokenization, representing a digital claim on a physical carbon credit held in custody by an accredited custodian. This structure ensures a one-to-one correspondence between the issued token and…

05/15/20260Comments

ByOleg Turceac