Google’s main Irish unit handled transactions worth €28.7 billion over three years as part of an international tax avoidance scheme, company documents show.
The documents, filed to the Dutch authorities, reveal the scale of Google’s financial operations in Dublin for the first time.
The company has been embroiled in controversy for years over its efforts to avoid tax on the profits made by its internet search engine and advertising operations. These controversies – and others surrounding firms such as Apple – have fanned criticism of Ireland’s corporate tax regime.
‘Double Irish’
Google employs more than 2,200 people in Dublin, which serves as its headquarters for Europe, the Middle East and Africa. The bulk of the tax liability on profits in these regions is borne by the Dublin unit, but it deploys a scheme known as the “double Irish” to reduce the ultimate tax bill. In late 2014, in the face of international pressure, the Government moved to phase out the double Irish, but it remains in place until the end of 2020 for companies already using it.
The scheme plays on differences between tax law in Ireland and other jurisdictions such as the tax haven of Bermuda. As a result, Google can cut tax payments by moving money between subsidiaries in different countries.
The main Irish entity in these arrangements is a company called Google Ireland Holdings, owned by Google in Bermuda. This is an unlimited company for which financial information has not been publicly available since 2006.
However, the scale of its operations has now emerged via the reporting of transactions with a subsidiary called Google Netherlands Holdings BV.
Royalty expenses
Financial accounts for Google Netherlands Holdings, which has no employees, show it paid royalty expenses of €10.7 billion to Google Ireland Holdings in 2014 and €9.2 billion in 2013. The royalty expenses in 2012 were €8.8 billion. These payments ranked among numerous transactions between the Netherlands and Ireland. The accounts show the same Dutch entity received €9.2 billion in royalty income in 2014 from a separate Irish company called Google Ireland Ltd.
There was no comment last night from Google’s spokeswoman on the filings in the Netherlands. “Google complies with the tax laws in every country where we operate,” she said.
