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Tag: MNEs

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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

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Carbon Credit MarketCarbon Credit Market ESG Data ServicesESG Data Services

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 carbon credit investment. This analysis, based on quantitative modeling and international tax doctrine, demonstrates three key effects: Pillar Two erodes the tax value of tokenized carbon credits by neutralizing non-refundable tax credits and ESG incentives…
05/09/20260Comments

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