Income Inclusion Rule (IIR)

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…

1 month ago

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…

1 month ago

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…

2 months ago