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Tag: IIR

STEELLDYThrough Steelldy consulting company, I assist companies, fintechs, and institutions in two key areas: ◙ Economic and financial statistical modeling via our DaaS & SaaS software (macroeconomic index platform). Analysis of the transition to a multipolar world: stablecoins, gold, copper, precious metals, industrial metals, oil, dollars, euros, yuan, yen, rubles, CBDC, BISIH, mBridge, Unified Ledger, BRICS, and global regulations. ◙ Web3 Law & Taxation Legal and Tax structuring of blockchain-based projects, RWA, tokenization, cryptocurrency (stablecoins, CBDC), decentralized autonomous organizations (DAO), MiCA compliance, ISO 20022, AI, MANBRIC/biotech technologies, robotics, smart cities, and ESG taxonomy.

Carbon Credit Market

Climate

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%…

4 days ago0Comments

ByOleg Turceac

Analyse de marché

Markets

Intangible Asset Shifting (IAS) Module

The Real Asset Shifting (RAS) module (www.steelldy-indices.com) focuses on tangible assets, notably cross-border real estate. However, intangible assets (patents, trademarks, software, know-how, databases, client lists) are historically the main channel for profit shifting in multinational groups. Unlike tangible assets, intangibles do not significantly benefit from the Substance-based Income Exclusion (SBIE), are highly sensitive to transfer…

07/01/20260Comments

ByOleg Turceac

Legal and tax studies

Regulatory Fundamentals and Architecture of Pillar Two in France | Operational Mechanisms of the GloBE Regime

1.1 Minimum Effective Tax Rate of 15% and calculation of the top-up tax Pillar Two of the OECD framework on international tax reform introduces a minimum effective tax rate of 15% applicable to the profits of multinational enterprises (MNEs) with consolidated revenue exceeding 750 million euros. This mechanism, formalized in the GloBE (Global Anti-Base Erosion)…

05/20/20260Comments

ByOleg Turceac

Carbon Credit Market

Pool Tokens: Stochastic Modeling of the Impact of Pillar Two (OECD) on Tax Engineering and the Valuation of Tokenized Carbon Investments

1.1 Collective Structuring and Pooling of Heterogeneous Quality Carbon Credits Pool tokens represent a stake in a collective portfolio of carbon credits with heterogeneous characteristics, structured as a mutual fund or a collective investment vehicle. This form of tokenization allows for the pooling of risks specific to each carbon credit and offers increased liquidity compared…

05/18/20260Comments

ByOleg Turceac