Google to end ‘Double Irish, Dutch Sandwich’

  • Changing procedure: Google is bringing to an end its use of a strategy that saw a chunk of its non-US generated revenue transferred to its Bermudian-registered entity Google Ireland Holdings Unlimited Company (Photograph by Virginia Mayo/AP)

    Changing procedure: Google is bringing to an end its use of a strategy that saw a chunk of its non-US generated revenue transferred to its Bermudian-registered entity Google Ireland Holdings Unlimited Company (Photograph by Virginia Mayo/AP)


Google is ending its tax strategy called the “Double Irish, Dutch Sandwich”, which saw it move billions of dollars to Bermuda.

The tech company moved $24.5 billion (€21.8 billion) through its Netherlands holding company to Bermuda in 2018, up from $22.7 billion the previous year, according to filings in the Netherlands that have been seen by Reuters.

The Double Irish, Dutch Sandwich procedure is legal, but it has been criticised in the past as an arrangement that allows Google to reduce its foreign tax bill.

Google parent Alphabet will no longer use the “sandwich” intellectual property licensing scheme, which allowed it to delay paying US taxes, according to its 2018 tax filings.

A Google spokesman has confirmed it would scrap the licensing structure, saying this was in line with international rules and followed changes to US tax law in 2017, Reuters reported.

In the past, the company’s revenue from royalties earned outside the US was moved through its subsidiary Google Netherlands Holdings BV to Google Ireland Holdings, which is registered in Bermuda. That allowed the company to avoid triggering US income taxes or European withholding taxes on the funds.

But under pressure from the European Union and the US, Ireland decided to phase out the arrangement, bringing an end to Google’s Irish tax advantages as of this year.

In addition, the US Tax Cuts and Jobs Act, which came into effect two years ago, means US companies’ foreign profits that have been made and taxed abroad are not subject to taxation when returned to the US.

Reuters reported that Google’s filing in the Dutch Chamber of Commerce, said: “A date of termination of the company’s licensing activities has not yet been confirmed by senior leadership, however, management expects that this termination will take place as of 31 December 2019 or during 2020.

“Consequently, the company’s turnover and associated expense base generated from licensing activities will discontinue as of this date.”

In a statement, a company spokesman said: “We’re now simplifying our corporate structure and will license our IP from the US, not Bermuda.”

The company said its global effective tax rate has been more than 23 per cent during the past ten years.

While Bermudian-registered Google Ireland Holdings Unlimited Company will no longer continue licensing intellectual property or holding debt securities, it will continue equity investment operations, according to a filing.

Four years ago, a number of newspapers in Britain put Bermuda under the spotlight regarding the billions of dollars sent to the island by Google.

The Sun on Sunday highlighted how Google directed billions of dollars of profits a year to the island, and noted the company’s only physical presence in Bermuda was a post office box, numbered 666, located at the General Post Office in Hamilton. The newspaper explained how Google Bermuda Unlimited and Google Ireland Holdings were registered at the address of law firm Conyers Dill and Pearman, on Church Street.

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Published Jan 2, 2020 at 12:01 am (Updated Jan 2, 2020 at 8:21 am)

Google to end ‘Double Irish, Dutch Sandwich’

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