OK, I am still confused. Let’s start here: You say that nothing yet exists, but I infer that there does exist some upstream panel that will be feeding the two new panels you have been discussing. Within that upstream panel, there will be a breaker that will serve the first of your two new panels. What is that breaker’s rating? Next, what is the ampacity of the wire from that breaker to the first panel? If I were designing this setup, my answers to those two questions would be, 225 amps, and 4/0, in that order.
Part of my confusion is that I think you are using the word “tap” as though it meant the same thing as “connect a wire to.” It does not. Rather, it means something like "connect a smaller wire to a bigger wire." Specifically, when you connect a new wire to an existing wire, you only call it a “tap” if the ampacity of the second wire is lower than the trip rating of the breaker that is protecting the first wire. In other words, if in your situation you have a 225 amp breaker that is protecting a 4/0 wire that serves the first 225 amp panel, and if you connect another 4/0 wire from the first panel to the second panel, then you do not have a “tap” situation. The second wire would be adequately protected by the 225 amp breaker.
Now, if you wanted to use a smaller wire than 4/0 from the first panel to the second panel, that smaller wire would not be adequately protected by the upstream 225 amp breaker. You are allowed to do that if you follow the tap rules in 240.21. But you are feeding a 225 amp panel, so why would you want to feed it with a wire that does not have the full 225 amp ampacity?