1.1 Economic and Legal Basis for the Exclusion of Intangible Assets
The concept of the "substance trap," formalized by STEELDY in their research on the interaction between Pillar Two and environmental tokenization, refers to a situation where an investment vehicle holding highly intangible assets is structurally unable to reduce its tax base through the SBIE…
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…