tangible assets

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…

4 days ago

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,…

1 week ago

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)…

2 months ago

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…

2 months ago

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…

4 months ago

Critical Analysis of the Gold‑Bitcoin Thesis: Orchestrated Decorrelation Strategy

[1] The note outlines a macro strategy linking (i) Gold, (ii) Bitcoin (BTC) and (iii) Capital Rotation. [2] Gold at…

10 months ago