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)…
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…