Google shifts $10b into Bermuda subsidiary to slash tax bill
NEW YORK (Bloomberg) — Google avoided about $2 billion in worldwide income taxes in 2011 by shifting $9.8 billion in revenues into a Bermuda shell company, almost double the total from three years before, filings show.
By legally funneling profits from overseas subsidiaries into Bermuda, which doesnt have a corporate income tax, Google cut its overall tax rate almost in half. The amount moved to Bermuda is equivalent to about 80 percent of Googles total pretax profit in 2011.
The increase in Googles revenues routed to Bermuda, disclosed in a November 21 filing by a subsidiary in the Netherlands, could fuel the outrage spreading across Europe and in the US over corporate tax dodging. Governments in France, the UK, Italy and Australia are probing Googles tax avoidance as they seek to boost revenue during economic doldrums.
Last week, the European Unions executive body, the European Commission, advised member states to create blacklists of tax havens and adopt anti-abuse rules. Tax evasion and avoidance, which cost the EU one trillion euros ($1.3 trillion) a year, are scandalous and an attack on the fundamental principle of fairness, Algirdas Semeta, the ECs commissioner for taxation, said at a press conference in Brussels.
The tax strategy of Google and other multinationals is a deep embarrassment to governments around Europe, said Richard Murphy, an accountant and director of Tax Research LLP in Norfolk, England. The political awareness now being created in the UK, and to a lesser degree elsewhere in Europe, is: Its us or them. People understand that if Google doesnt pay, somebody else has to pay or services get cut.
Google said it complies with all tax rules, and its investment in various European countries helps their economies. In the UK, we also employ over 2,000 people, help hundreds of thousands of businesses to grow online, and invest millions supporting new tech businesses in East London, the Mountain View, California-based company said in a statement.
The Internet search giant has avoided billions of dollars in income taxes around the world using a pair of tax shelter strategies known as the Double Irish and Dutch Sandwich, Bloomberg News reported in 2010. The tactics, permitted under tax law in the U.S. and elsewhere, move royalty payments from subsidiaries in Ireland and the Netherlands to a Bermuda unit headquartered in a local law firm.
Last year, Google reported a tax rate of just 3.2 percent on the profit it said was earned overseas, even as most of its foreign sales were in European countries with corporate income tax rates ranging from 26 percent to 34 percent.
At a hearing last month in the UK, members of Parliament pressed executives from Google, Seattle-based Amazon.com Inc. and Starbucks to explain why they dont pay more taxes there.
The UK, Googles second-biggest market, was responsible for about 11 percent of its sales, or almost $4.1 billion last year, according to company filings. Google paid £6 million ($9.6 million) in UK income taxes.
Matt Brittin, Googles vice-president for Northern and Central Europe, testified that the company pays taxes where it creates economic value, primarily the US.
Still, Google attributes some profit based on technology created in the US to offshore subsidiaries, lowering its US taxes, according to company filings and people familiar with its tax planning. Google paid $1.5 billion in income taxes worldwide in 2011.
In the wake of the parliamentary hearing, the House of Commons issued a report last week declaring that multinationals do not pay their fair share of tax. The committee also criticised the UKs tax collection agency, Her Majestys Revenue & Customs, for not taking sufficiently aggressive action and called on the agency to get a grip on corporate tax avoidance.
A spokesman for HMRC said the agency ensures that multinationals pay the tax due in accordance with UK tax law.
The French tax authority this year proposed increasing Googles income taxes by about $1.3 billion. The agency searched Googles Paris offices in June 2011 and removed computer files as part of an examination first reported by Bloomberg last year. Google is cooperating with French authorities and works with them to answer all their questions on Google France and our service, the company said.
In Italy, the Tax Police began an audit of Google last month and recently searched the companys Milan offices, as well as the offices of Facebook, according to a person familiar with the matter. Its very common for companies to be audited, and we have been working closely with the Italian authorities for some time, Google said. So far we have not had any demands for additional tax in Italy.
Facebook, based in Menlo Park, California, is cooperating with the Italian tax authority and we take our obligations under the Italian tax code very seriously, a company spokeswoman said.
In Australia, the countrys assistant treasurer gave a speech last month outlining Googles tax avoidance strategies.
The use of offshore shelters to avoid corporate taxes has prompted calls for reform in the US as well. The Treasury Department has repeatedly proposed since 2009, with little success, to make it harder for multinationals to bypass taxes by shifting profit into tax havens.
Multinational companies cut their tax bills using transfer pricing, paper transactions among corporate subsidiaries that allow for allocating income to tax havens and expenses to higher-tax countries.
In Googles case, an Irish subsidiary collects revenues from ads sold in countries like the UK and France. That Irish unit in turn pays royalties to another Irish subsidiary, whose legal residence for tax purposes is in Bermuda.
The pair of Irish units gives rise to the nickname Double Irish. To avoid an Irish withholding tax, Google channelled the payments to Bermuda through a subsidiary in the Netherlands — thus the Dutch Sandwich label. The Netherlands subsidiary has no employees.
The Dutch units payments to the Bermuda entity last year were up 81 percent to $9.8 billion from $5.4 billion in 2008. Googles overseas sales have increased at about the same rate.
Googles overall effective tax rate dropped to 21 percent last year from about 28 percent in 2008. That compares with the average combined US and state statutory rate of about 39 percent.
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