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%…
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…
Carbon Credit Market