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‘Double Irish’ & ‘Dutch Sandwich’ loopholes saved Google at least $3.7 billion in 2016 taxes

A common critique of Google, and frankly most major multinational companies, is the reliance on loopholes to reduce international taxes. The same process occurred in 2016 with tax shelters saving Google at least $3.7 billion in taxation.

According to Dutch regulatory filings (via Bloomberg) that finally went public, Google moved $19.2 billion in revenue to a Bermuda shell company in 2016. In turn, those loopholes — which shield a majority of its international profit from taxation — saved the company at least $3.7 billion in taxes for an effective tax rate of 19.3 percent, according to SEC filings for 2016.

The “Double Irish” loophole involves moving revenue from an Irish subsidiary to a Bermuda mailbox owned by a different company registered in Ireland through an employee-less Dutch company (the “Dutch Sandwich”).

Google Ireland Ltd. collects most of the company’s international advertising revenue and then passes this money on to Dutch subsidiary Google Netherlands Holdings BV. A Google subsidiary in Singapore that collects most of the company’s revenue in the Asia-Pacific region does the same.

Compared to the prior year where data is available, there was a seven percent increase in money funneled through this structure, with Google shaving $3.6 billion in taxes for 2015.

With mounting criticism from the European Union, the “Double Irish” was halted in 2015 by Ireland, though existing companies can use the structure until 2020. Meanwhile, Google continues to argue that it abides by all international tax laws.


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Avatar for Abner Li Abner Li

Editor-in-chief. Interested in the minutiae of Google and Alphabet. Tips/talk: abner@9to5g.com