Executive Summary
The 3:2:1 crack spread serves as a primary proxy for gross refining margins, calculated as:
3:2:1 Crack Spread=2×PGasoline (bbl)+1×PDistillate/Heating Oil (bbl)−3×PCrude (bbl)3\text{3:2:1 Crack Spread} = \frac{2 \times P_{\text{Gasoline (bbl)}} + 1 \times P_{\text{Distillate/Heating Oil (bbl)}} - 3 \times P_{\text{Crude (bbl)}}}{3}
where prices are typically futures-settled (e.g., WTI/RBOB/NYH HO for USGC benchmarks; Brent equivalents or regional baskets for Europe).…
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)…
Oil reserves are rapidly depleting, eroding the world's crucial buffer against supply shocks. A concerning JP Morgan chart, discussed by David Russell of GoldCore and featured in Bloomberg, illustrates the drastic decline in total discovered oil reserves, measured in billions of barrels.
These reserves initially built up during the COVID-19 pandemic when demand plummeted,…
The impact of the Pillar Two international tax regime (OECD) on the valuation and structuring of tokenized carbon credit (TCC) investments, particularly in France.
(A) Structural effect of Pillar Two on the taxation of TCCs
¤ Pillar Two imposes a minimum effective rate of 15% on the profits of multinational corporations, neutralizing tax optimization…
CBDC interoperability challenges—particularly in hybrid setups like the Société Générale–Forge/Banque de France (BdF) 2024 repo pilot and ongoing Les Gardiennes/UBS collaborations—stem from bridging public Ethereum (permissionless, for tokenized collateral like bonds or uMINT funds) with proprietary/permissioned CBDC ledgers (e.g., BdF’s DL3S on Hyperledger Fabric). These pilots use mechanisms like Hashed Timelock Contracts (HTLCs), APIs, and…
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