Top-Up Tax

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…

2 weeks ago

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…

3 weeks 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,…

3 weeks ago

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…

3 weeks ago

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…

2 months ago

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…

2 months ago

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…

2 months ago

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…

2 months ago

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…

2 months ago

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…

2 months ago