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Tag: Substance-Based Income Exclusion (SBIE)

HomeAll PostsTag: Substance-Based Income Exclusion (SBIE)
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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Papers with financial graphs beside stacks of US dollar bills representing market analytics.
Analyse de marchéAnalyse de marché MarketsMarkets

How High-Value Properties Slash Pillar Two Top-Up Tax Under SBIE Rules

The Substance-based Income Exclusion (SBIE) is a carve-out mechanism under Pillar Two (GloBE) that excludes part of a jurisdiction's GloBE Income before calculating top-up tax, recognizing real economic substance. Its formula for 2022 rules with 2024-2026 guidance is 5% of eligible payroll plus 5% of tangible assets' carrying value. Payroll includes eligible employee expenses,…
06/30/20260Comments

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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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