Pillar Two · OECD BEPS 2.0
Pillar Two: Operationalising the Global Minimum Tax and Its Impact on Holding Structures
The global minimum tax of 15% (Pillar Two / GloBE) has been in force in over 50 jurisdictions since 2024. This article analyses implementation differences, the Income Inclusion Rule, the Qualified Domestic Minimum Top-up Tax and the practical consequences for cross-border holding architectures.
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Private Credit · Basel IV · CRR3
Private Credit and Basel IV: The Structural Transformation of Debt Capital Markets
Basel IV / CRR3 (effective January 2025) permanently increases risk weightings for corporate loans and reduces bank capacity in the mid-cap segment. Private debt funds are absorbing this capacity gap. An analysis of market growth, yield structures and the regulatory framework.
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Tokenisation · Securitisation · DLT
Digital Asset-Backed Finance: Tokenisation and Granular Securitisation of Trade Receivables
AI-powered platforms securitised trade receivables in near real-time in 2024, opening direct access to supply-chain risk profiles for institutional investors for the first time. This article examines the technological foundations, regulatory frameworks (EU DLT Pilot Regime) and investment potential.
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PE Secondaries · NAV · Continuation Vehicles
PE Secondaries and NAV Financing: Liquid Solutions for Illiquid Portfolios
The PE secondary market surpassed $150 billion in volume for the first time in 2024. NAV facilities and continuation vehicles are transforming general partners' liquidity strategies. A structured analysis of the instruments, their tax implications and market development through 2026.
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