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Analyse de marchéAnalyse de marché MarketsMarkets

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

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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

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

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Legal and tax studies

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 on its Geneva trading subsidiary. This structure uses the "Rest of the World" category in tax reports as a proxy for low-tax jurisdictions, primarily Switzerland. The implementation of the OECD Pillar Two GloBE rules,…
05/09/20260Comments

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