Calculation of the Effective Tax Rate under Pillar Two

1.1 Formal Specification of the GloBE ETR The determination of the Effective Tax Rate (ETR) under the GloBE regime follows a formal specification whose mathematical precision conditions the entire tax calculation chain. The ETR per jurisdiction, denoted ETR_j for jurisdiction j, is defined by the ratio: ETR_j = ACT_j / GI_j, where ACT_j represents the…

8 hours ago0Comments

ByOleg Turceac

The GloBE Regime and Its Structural Implications for Tokenized Assets

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%…

4 days ago0Comments

ByOleg Turceac

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

ByOleg Turceac