Skip to content Skip to sidebar Skip to footer

Tag: Top-Up Tax

STEELLDYThrough Steelldy consulting company, I assist companies, fintechs, and institutions in two key areas: ◙ Economic and financial statistical modeling via our DaaS & SaaS software (macroeconomic index platform). Analysis of the transition to a multipolar world: stablecoins, gold, copper, precious metals, industrial metals, oil, dollars, euros, yuan, yen, rubles, CBDC, BISIH, mBridge, Unified Ledger, BRICS, and global regulations. ◙ Web3 Law & Taxation Legal and Tax structuring of blockchain-based projects, RWA, tokenization, cryptocurrency (stablecoins, CBDC), decentralized autonomous organizations (DAO), MiCA compliance, ISO 20022, AI, MANBRIC/biotech technologies, robotics, smart cities, and ESG taxonomy.

Climate

ESG Data Services

Comparative Analysis and Mapping of Tax Risks

1.1 Tripartite Classification Framework for Carbon Credit Tokens The taxonomy of Carbon Credit Tokens (CCTs) proposed by STEELLDY is structured around three fundamental categories, each presenting a distinct tax risk profile under the Pillar Two framework. This tripartite classification | direct possession tokens, pool tokens, and synthetic tokens | constitutes an essential analytical framework for…

07/06/20260Comments

ByOleg Turceac

Climate

The GloBE Regime and Its Structural Implications for Tokenized Assets

Genesis and Legal Foundations of Pillar Two in the OECD/G20 Framework Pillar Two, the product of the OECD/G20 work on base erosion and profit shifting (BEPS 2.0), constitutes the most ambitious reform of international taxation since the OECD and UN model conventions. Its stated objective is to establish a minimum effective tax rate of 15%…

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…

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

ByOleg Turceac

Carbon Credit Market

The STEELLDY CCQI Index: Methodology and Function as a Fiscal Barometer. (a) Climate Credit Quality Index (CCQI) Architecture

1.1 Proprietary Multidimensional Benchmark Evaluating the Integrity, Durability, and Liquidity of Carbon Credits The Climate Credit Quality Index (CCQI) developed by STEELLDY is a next-generation proprietary benchmark specifically designed to address the transparency and standardization gaps characterizing the voluntary carbon credit market. Unlike traditional indices, which are limited to price aggregations or transaction volumes, the…

05/21/20260Comments

ByOleg Turceac

Legal and tax studies

Regulatory Fundamentals and Architecture of Pillar Two in France | Operational Mechanisms of the GloBE Regime

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)…

05/20/20260Comments

ByOleg Turceac

Carbon Credit Market

Synthetic Tokens : Stochastic Modeling of the Impact of Pillar Two (OECD) on Tax Engineering and the Valuation of Tokenized Carbon Investments

1.1 Replicating Carbon Price Exposure Without Physical Holding of Credits Synthetic tokens offer exposure to carbon credit prices without requiring the physical holding of the underlying credits, by using derivative mechanisms such as futures contracts, total return swaps, or price oracles that replicate the performance of a carbon market benchmark index. This structure offers advantages…

05/19/20260Comments

ByOleg Turceac

Carbon Credit Market

Pool Tokens: Stochastic Modeling of the Impact of Pillar Two (OECD) on Tax Engineering and the Valuation of Tokenized Carbon Investments

1.1 Collective Structuring and Pooling of Heterogeneous Quality Carbon Credits Pool tokens represent a stake in a collective portfolio of carbon credits with heterogeneous characteristics, structured as a mutual fund or a collective investment vehicle. This form of tokenization allows for the pooling of risks specific to each carbon credit and offers increased liquidity compared…

05/18/20260Comments

ByOleg Turceac

Carbon Credit Market Digitalisation

Taxonomy and Characterization of Carbon Credit Tokens (CCTs)

1.1 Direct Ownership Tokens 1.1.1 On-chain Representation of Carbon Credits Held in Custody by the Investor Direct ownership tokens constitute the most fundamental form of carbon credit tokenization, representing a digital claim on a physical carbon credit held in custody by an accredited custodian. This structure ensures a one-to-one correspondence between the issued token and…

05/15/20260Comments

ByOleg Turceac

Cryptos

Integration of the CCQI Index into Credit Risk Models

1.1 Adaptation of the Merton Model: Adjustment of the Probability of Default (PD) using the CCQI Index The integration of the CCQI Index into credit risk models relies on adapting the structural framework of Merton (1974), where a borrower's Probability of Default (PD) is determined by the distance between the value of their assets and…

05/12/20260Comments

ByOleg Turceac