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Google's Irish-Dutch sandwich grew to €8.8bn in 2012 with
transferred from Ireland via the Netherlands to an Irish company in Bermuda with
a physical presence on the island that amounts to a letter box in the offices of
an offshore services company.
The Financial Times
reports today that
the latest figures come from the
accounts of Google Netherlands Holdings, which represents the “Dutch sandwich”
part of the tax structure. It received €8.6bn in royalties from Google Ireland
Ltd and €232.8m in royalties from Google’s Singapore operation. All but €10.4m
of this was paid out to Google Ireland Holdings, a company that is incorporated
in Ireland but technically controlled in Bermuda, where there is no corporation
The FT says that differences between the Irish and US tax codes mean that
this dual-resident company is viewed as Irish for US tax purposes but Bermudan
for Irish purposes. It acquired much of Google’s intellectual property in 2003,
which it licensed to Google Ireland Ltd, a Dublin-based business that is at the
heart of its global operation. The business, which employed 2,199 people last
year, paid €17m in Irish corporation tax, having reported pre-tax profits of
€153.9 on turnover of €15.5bn.
"Stateless" Irish companies used by Apple and Google are not Ireland's
Google's provision of €17m in corporate tax in 2012 to Ireland on the foreign
net income of $8.1bn it booked in Ireland, gave an effective tax rate of
Google's foreign-paid tax rate in 2012 was 4.4%.
Süddeutsche Zeitung, the German newspaper, reported that the SPD opposition
party, which is in talks with Angela Merkel's CDU-CSU conservative grouping on
the formation of Germany's next government, is opposed to use of the European
Stability Mechanism rescue fund for recapitalisation of Irish banks or the assumption
of responsibility for the legacy bank-related debt burden, without conditions.
“We say that whoever wants a common resolution
fund must agree to a financial transaction tax,” Carsten Schneider, SPD budget
spokesman in the German parliament, told the Financial Times.
Schneider also said Ireland would have to agree
to raise its headline 12.5% rate of corporation tax - - however, this would do
nothing to change the most egregious examples of tax avoidance.