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Tag: tangible assets

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…

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Stochastic Modeling of the Impact of Pillar Two (OECD) on Tax Engineering and the Valuation of Tokenized Carbon Investments (TCC): Correlation Analysis Between STEELLDY’s CCQI Index and the Risk-Adjusted Tax Performance of TCCs in French Jurisdiction

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…

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Pillar Two’s Silent Killer: How GloBE Rules Decimate Tax Benefits for Tokenized Carbon Credits

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…

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Systemic Revaluation of Tangible Assets: Why Gold and Gold Miners Dominate the Market (“The Great Rotation into Reality”)

The current outperformance of gold (XAU) and mining stocks over the rest of the market (especially technology) is not a temporary anomaly. It results from the "double commoditization" of AI and software, which is destroying the monetization model of intellectual capital. As intelligence becomes a cheap and widely available commodity, the physical resources needed to…

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