Google tax-free income in 'double Irish, Dutch Sandwich'

Google moved €10.7 billion through the Netherlands to Bermuda in 2014, as part of a structure which allows it to earn most of its foreign income tax-free.

Accounts for Google Netherlands Holdings show the unit transferred almost all its revenue, mainly royalties from an Irish affiliate through which most non-US revenue is channelled, to a Bermuda-based, Irish-registered affiliate called Google Ireland Holdings.

The strategy is known to accountants as the “double Irish, Dutch Sandwich”.

Google said it follows the tax rules in all the countries where it operates.

The decade-old arrangement allowed Alphabet to enjoy an effective tax rate of just 6% on its non-US profits last year.

Corporate tax avoidance has risen to the top of the political agenda in Europe in recent years.

Google paid a British tax bill for 2005-2015 of around £200m, but its UK revenue amounted to £24bn. Google Netherlands Holdings, which has no employees, had a €2.8m Dutch tax bill.


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