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Google Cuts Taxes By Shifting Billions to Bermuda—Again

Jan. 3, 2019, 9:39 PM

Google Inc. continued to reduce its taxes for another year by taking advantage of loophole structures—this time shifting $22.6 billion.

The world’s largest search engine and subsidiary of Alphabet Inc. moved 19.9 billion euros in 2017 to Bermuda through intercompany transactions flowing from a shell company in the Netherlands, according to a filing by Google Netherlands Holdings B.V. with the Dutch Chamber of Commerce.

The information comes as tax authorities around the world blast Google for not paying enough tax.

Google used a “Double Irish” with a “Dutch Sandwich” structure to steer its international profits away from higher tax jurisdictions. Under such arrangements, a company shifts revenue from an Irish company to a Dutch company that has no employees, which then shifts that revenue to a Bermuda mailbox owned by another Irish company.

The company used this method in prior years as well, moving 15.9 billion euros to Bermuda in 2016, 14.9 billion euros in 2015, and 10.7 billion euros in 2014.

Google Netherlands Holdings Has No Employees

Google Ireland Limited and Singapore-based Google Asia Pacific Pte. Limited made royalty payments to Google Netherlands Holdings B.V., the Dec. 21, 2018 filing said. The Dutch shell company then paid that royalty amount to Google Ireland Holdings Unlimited Co.

Google Netherlands Holdings has no employees and is a subsidiary of Google Ireland Holdings. The latter is incorporated in Ireland but is managed and controlled from Bermuda, according to a May 2018 document from the United Nations Economic and Social Council.

Irish law in 2015 stopped companies from taking advantage of such a structure, but companies with current structures like this can continue to use them until 2020.

Google’s global effective tax rate over the last 10 years was 26 percent, according to a Google spokesperson.

“Google pays corporate income tax globally, but the vast majority of our corporate income tax is paid in the United States,” the Google spokesperson told Bloomberg Tax in a statement.

--With assistance from Joost Akkermans in Amsterdam, Alexandra Stratton in New York and Jeremy Kahn in London (Bloomberg)

To contact the reporter on this story: Sony Kassam in Washington at (Bloomberg Tax)

To contact the editor responsible for this story: Kevin A. Bell at