back to article Google slips $3.1bn through 'Double Irish' tax loophole

Google has saved $3.1bn in taxes since 2007 by shuttling its foreign profits through Ireland and the Netherlands, then on to a haven in Bermuda, according to the company's regulatory filings. As reported by Bloomberg Businessweek, Google uses techniques known as "Double Irish" and "Dutch Sandwich" to lower its foreign tax rate …


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  1. Anonymous Coward
    Anonymous Coward

    and SAP makes up the six AMIGOS ;)

    has to be a token representative of the Euro zone

    1. citizen.joan

      Goodbye Google

      Hello Bing........Goodbye Google. Yes, msft knows how to use the tax code, but they paid more taxes and Gates donates billions to charity.

  2. Anonymous Coward
    Anonymous Coward

    the five AMIGOs

    the software "Big Five": Apple, MSFT, IBM, Google, Oracle :) all tax cowboys south of the border.

  3. Neal 5


    The difference between illegal and legal, and of course how you view it. The "big" five criers when it comes to being slapped on the wrists.

  4. Yet Another Anonymous coward Silver badge


    So if somebody were to invade Bermuda or Sark (say looking for weapons of mass destruction) they could gain control of all the worlds largest companies ?

    Sounds like a good ROI for a defence ministry looking to make up for some cuts.

    1. Blue eyed boy

      But whoever invaded, they would also find

      their own dirty linen among the now-public wash.

  5. Dave 52

    I guess it's legal...

    When you pay off legislators across the world to come up with the laws to make it so. If you're a regular Joe, and pay your taxes while the rich elites pay almost nothing, what does that make you?

    1. Geoff Campbell Silver badge

      "What does that make you?"



    2. Shadowmanx2009

      A Mug!

      ...As we're the ones funding the excessive spending of Government!

  6. streaky


    Any Irish people reading, this is why you're bankrupt...

    1. deadlockvictim


      @streaky » The Irish are bankrupt because they didn't regulate their banks and then poured their life savings into the gutter. The Irish department of finance showed the financial acumen of a 4-year-old in a sweetshop.

      1. Anonymous Coward
        Anonymous Coward

        Common practice

        The small NASDAQ-listed minnow I once worked for also did the Ireland-Bermuda trick. The Emerald Isle profited by three job reqs and the US lost millions in tax revenue.

    2. Tonik

      re: streaky

      Right, google came to Ireland, built offices, gave people work and paid 2.5% of 12 billion to Irish government. And that bankrupt them, the irish people reading.

    3. Anonymous Coward

      The Irish gov

      And meanwhile the Irish gov is garnishing 6% on top of tax from every working taxpayer in Ireland. Oh, and increasing tax to 42% next year. Oh, and taking money from the allowances that we pay PRSI for. Oh, and..

      The list goes on. It's funny, like watching a 2yr old trying to balance a checkbook for a multibillionaire. At least it would be funny if they weren't fecking our economy up.

      Funny thought. Since they're garnishing an average €100 for the million or so working people in the country, several "corner shop" franchises have reported losing income. There's almost a direct correlation to the money they're stealing from the taxpayer to the amount of reported profit loss - and subsequent unemployment - which leads to higher taxes and more levies - which leads to more of these firms closing out - etc.

      The dumbest bunch of politicians I think anyone's ever seen.

      1. Anonymous Coward
        Anonymous Coward

        Its begs the question - who in their right mind would stay in Ireland?

        Assuming they had the means of emigrating.

  7. Martin 49

    A bit of both, probably.

    Morality aside.....

    Tax EVASION is illegal. Tax AVOIDANCE is not.

    Most big corporates walk a very fine line between the two.

    Someone once dubbed this AVOISION.

    1. Velv

      Best summed up

      What's the difference between tax evasion and tax avoidance ?

      About five years in jail.

    2. gotes


      > Someone once dubbed this AVOISION

      Kent Brockman?

      1. TeeCee Gold badge

        Re: Avoision

        George W Bush?

    3. Rob

      Completely agree...

      ... in short this is legal money laundering to a certain extent.

    4. Anonymous Coward

      "Someone once dubbed this AVOISION."

      But they were drunk in a Dublin pub.

  8. bitten

    the irish black hole

    for years ireland has sustained itself by offering tax cuts on foreign incomes

  9. Anonymous Coward
    Thumb Up

    Even so

    You gotta admire the tax acountants who worked out how to do this. Those are some seriously devious people

    1. JimC

      ...Seriously Devious

      I the long distant past as a biology student I learned that almost all the most complex life cycles are lived by parasites...

    2. Anonymous Coward
      Anonymous Coward


      can't think of a more admirable quality than being 'seriously devious'

      1. Marky W

        how about...

        ...seriously deviant?

    3. Jason Bloomberg Silver badge

      And probably very rich too

      Those who can help save millions, even billions, through 'legalised scams', no doubt get their slice from the pie and have very comfortable lives.

      As always, the rich get richer, the poor stay poor. While it partly is jealousy, there is real resentment that while we have to pay full rates of tax and duties, may go to prison if we don't, corporates will sneak far more than we could ever cheat on through the system and get applauded and patted on the back for having done so.

      While the issue is between legal and illegal, the real moral question is how can we allow it to be legal? It makes a mockery of the argument that taxes due must be paid and then let things like this go on.

    4. Anonymous Coward
      Anonymous Coward

      "...Those are some seriously devious people"

      Last time I checked, Google wasn't known for employing thick people (apart from the politicians, that is).

      Far from it.

  10. bitmap animal

    They wouldn't be there without the tax breaks

    If it wasn't for the tax breaks they wouldn't operate in RoI like that, they are not reducing the amount of tax they pay in RoI but in their native countries.

    As things stand they get a satelite office from these companies so do get some local gains and some tax income so the country is better off by doing this.

    I don't know the figures but say they get 0.1% of £1B that is much much more than 25% of nothing,

    1. DavCrav

      As citizens of other countries...

      ... we thank you for gifting Google the ability to not pay lots of tax from our countries so you can have a little of it.

      When you think about tax evasion/avoidance, think of the following maxim. There are only two people in the world: you and everyone else. When everyone else doesn't pay their fair share you have to pay more. People who use legal loopholes to make you and me pay more tax should not be applauded, but castigated.

  11. DB2k


    Seriously.. this is obscene.

  12. Dax Farrer

    Tax Avoidance

    "Google has its faults, but making use of a legal tax loophole isn't one of them. ®"

    Actually it is evil.

    Tax avoidance is just tax evasion that hasn't been found out yet.

    1. Dr. Mouse

      Not so

      "Tax avoidance is just tax evasion that hasn't been found out yet."

      Tax avoidance is using legal loopholes to pay less tax. Most of these loopholes are known by the govt. Therefore they have already been found out, but what they are doing is perfectly legal.

      Tax evasion is, basically, just not paying the taxes you owe. This is NOT legal.

      I am not saying it is right, moral or just. I am saying there is a distinct difference. If the govt wants to, they can introduce legislation to close the loophole. They (effectively) endorse tax avoidance (glad I proof read this, I initially wrote 'evasion' here) by not closing the loopholes.

      Many people avoid tax by legal means, for example setting up a limited company, taking minimum wage for them and their spouse, and then taking the rest in dividends avoiding national insurance and higher rate income tax. If you found a way to pay less tax on your wage, would you not do so?

      1. NogginTheNog

        This is a tricky line to draw though

        As a company, isn't it behoven to shareholders to maximise profits? So wouldn't NOT using advantageous tax regimes go against this obligation?

        Likewise countries are free to set their own taxation rate and laws. It's a fine balance between getting fair revenues from individuals and companies, and also not being too strict so as to drive the larger ones elsewhere. As someone earlier posted, better a smaller slice of a bigger pie...

  13. irish donkey

    Makes you feel better about downloading

    Well if they steal from my economy they I am going to do the same to you.

    Now if we could find a similar setup with the Movie/Music/IP producers (It has to be there) then that would re-open the whole debate about who is actually stealing from who...

    We want to know...

  14. Daren Nestor

    Irish corporate tax rate 28%?

    I thought it was 12.5%. Is the 28% some aggregate of all taxes, or just wrong?

    1. Danny 14


      its just a number pulled out of thin air. Thats how journalism works, pick a number. Although it rarely has "7's" in it. People get scared of numbers with 7's in it.

  15. Miek

    a tit is required

    Dear Google, please Pay your taxes, tax avoidance is 'evil'

  16. Anonymous Coward

    Governments are going to have to ...

    just start charging companies for the taxes that they are generated in that country, irregardless of how the money is routed afterward. The way the economy is going my taxes are going up and my pay will, if I'm lucky, stay the same. Any corporation that can boast huge profits had better start paying the appropriate taxes to the appropriate government or they'll find they are on many peoples will not use/buy list. We really need to get after our elected representatives about tax loopholes like these.

    1. bitmap animal

      re Governments are going to have to ... @ 09:44

      But the UK are taxing people on income earned abroad following big outcries that some people also have businesses in different countries and so were not paying UK tax on international money.

      Double tax, yay!!

    2. leftfield


      ... Come again?

  17. Graham Bartlett

    @Dax Farrer

    Tax avoidance is doing it legally. Tax evasion is doing it illegally. If governments make daft laws that explicitly allow for loopholes in where the taxation goes, they can expect to get reamed for it.

  18. Blofeld's Cat

    Phase one is complete....

    In phase two Bermuda raises their tax on foreign deposits to 500%...


  19. yoinkster
    Thumb Up

    Come on, hands up ...

    Who wouldn't be on the wind up to save themselves money if they knew how to?

    I don't like paying taxes and if I knew a legal way to channel my funds around so that I paid next to no tax you can damn well bet I would!

    It's not Google's fault for getting through the legal minefield unscathed, it's the lawmaker's fault for leaving the path open.

  20. James 93

    as usual

    Rich get richer, poor get poorer.

  21. Keith 21

    Do No Evil

    Yeah, right.

    Face facts, Google, you are just as "evil" as every other big corporation out there, and your tax avoidance schemes are just yet another piece of your corporate evil.

    It's time google admitted they are evil, and it's time all the fawning drooling Google-fans finally realised that the object of their worship isn't a kindly benevolent lone crusader in a sea of evil, but just another "evil" greedy corporation; a corporation which is getting away with it through those supporters' own gullability.

  22. myhandle
    Thumb Up

    What's it called

    So it's a sort of reverse dutch steamboat for taxes ?

  23. Anonymous Coward

    Full Throttle quote...

    I just remembered this priceless gem of this vintage game. LucasArts knew gaming back then.

    "- But Malcolm, isn't that illegal?

    -Not back then, no it wasn´t. "...

    google for it. Oh the irony.

  24. Graham Anderson

    No corporation tax in the UK

    Being an "Irish" company, Google pays no taxes on revenues generated from the sale of advertising by UK companies, to UK consumers on searches performed within the UK. The UK represents 12% of all of Google's revenues according to the last earnings release. This is perfectly legal.

    The Americans have particular reason to be upset at this arrangement as Brin & Page's research which gave rise to the technology behind Google was funded by the US taxpayer bankrolled National Science Foundation.

  25. Velv

    Anyone else ...

    Fancy a Double Irish Dutch sandwich ?

    1. TeeCee Gold badge

      Re: Anyone else

      Ok, I'll bite.........

    2. Anonymous Coward
      Paris Hilton

      How about a ...

      Dutch rudder?

  26. Graham Bartlett

    @Keith21: not necessarily

    What would the country do with the money? If the result of minimising taxes paid is that various countries have less money available for, say, invading other countries, or getting their police/army/paramilitaries to shoot civilians for the heinous crime of Loitering Whilst Black/Muslim/Irish, or subsiding institutionally-corrupt countries such as Greece, then it's all good. The corporation can then put that money into things that actually *do* benefit society.

    Pirates bcos they know what to do with taxmen.

  27. James Micallef Silver badge

    The genius bit on the part of the corporations and the rich.... that they are the ones that profit from a complex tax system with lots of tax breaks and tax credits because they can hire the best lawyers / accountants and have the resources to set up foreign subsidiaries etc... AND at the same time they publicly complain about high taxes.

    The result is that the beatnik / hippie / socialist / union / communist types continue to favour keeping the current tax system, while increasing rates for top earners and adding breaks / rebates for poor folks. In reality the way to make rich people and big corporations to pay their fair share is to have a flat tax rate with NO breaks / rebates.

    But this model is the one which the socialists will never accept... and also one which any politician will also never accept because it will put a million tax buereaucrats out of work AND cut off their corporate funding, all in one go.

    1. John H Woods Silver badge

      absolutely agreed

      Everyone gets 10,000 per year to keep them off the breadline. Everyone pays tax at, say, 30p on every single pound they earn beyond that. Tax departments streamlined by 90%, benefits departments reduced to dealing with a tiny minority of cases such as severe disability. No poverty trap because every hour you work makes you richer. If only ...

    2. Anonymous Coward

      Re: The genius bit on the part of the corporations and the rich....

      I don't agree with the view that "beatnik / hippie / socialist / union / communist types continue to favour keeping the current tax system", and that says a lot about your intolerant attitude towards anyone who doesn't "celebrate capitalism". The only thing that "socialists" favour is that people who earn less should pay much less tax, not that there are lots of different ways to "claim back" stuff: most people in the groups you mention don't have the time or inclination to spend hours poring over all the tax regulations looking for deduction opportunities.

      In fact, a lot of the deductions are about placating people who don't feel that they should be paying tax on stuff because they're special in some way, resulting in attitudes like "I drive my car to work, so I don't see why I can't have the car, the petrol, the tyres, the servicing, the parking charge, the fluffy dice, my new garage door, the new Top Gear DVD, all deducted as 'work expenses'." It's precisely this kind of 1980s-style "go getter" bullshit that the tax system rewards while it swallows up resources trying to support and occasionally police it.

      And the claim that the rich inadvertently benefit from such supposedly "socialist" complexity. Were you born yesterday?

    3. crypt

      Dont argue on the internet no one cares ,why do I forget this?

      "The result is that the beatnik / hippie / socialist / union / communist types continue to favour keeping the current tax system"

      There aren’t many beatniks in my local branch but I'll ask around the party at the National Conference in November.

      Socialists / Communists don’t want to keep the current tax system , we want to replace private ownership with total public ownership .If you would actually like to learn about socialist economics I could recommend many books , none by FA Hayek.

      Lets not even argue about flat tax, go have a look at some countries that have such a thing.

      for example Ukraine - where, in 2003, 4.9 percent of the Ukrainian population live under 2 US dollar a day and over 19% were below the poverty line.

      (public)Companies owe their shareholders profits ,they will accumulate these by cutting wages ,dodging tax or whatever legal means they can employ .

      Unfortunately I happen to live in a <strike>banana</strike> potato republic where our government is happy to garnish a small percentage of tax off large foreign corporations and risk long term economic instability rather than create employment directly, or failing that , incentivise companies to come here with a college educated populace and potentially guarantee lasting employment

      Incidentally Ireland doesn’t have "a million tax bureaucrats", we have , proportionately a small civil service compared to the rest of the EU.

      Apologies , I'm extremely off topic

  28. Aristotles slow and dimwitted horse

    The reason they get away with it is...

    Because ultimately the Governments get money both ways. A reduced amount from the large Corporation itself; but LOTS from the taxes deducted from the many local employees employed by the corporations. If these avoidance loopholes are closed, the corporations will move away from the UK and Government then realises that it is getting exactly 100% of sweet f*** all and higher unemployment figures to boot.

    1. leftfield

      Last time I checked...

      ....The Republic of Ireland wasn't part of the UK... hence it being a republic....

  29. Anonymous Coward

    It is disgusting they get away with it...

    I was sat here wondering how the UK will cope with the devastating cuts and loss of jobs. I then see this post and it really is sickening. Governments across the globe are struggling and yet these corporations use loopholes to stick two fingers up to all the rest of us.

    If I was the President or Prime Minister and I saw hundreds of Millions in tax being evaded I'd first start blocking these loopholes and then shame them on every TV channel...

    "Google and [another company name] and [another company name] tax avoidance could have built and staffed a thousand new hospitals, could have given our troops the equipment they desperately need, could have created thousands of new jobs, could have built homes for the homeless, could have repaired hundreds of schools across the country. Instead troops needlessly die, the sick get sicker and we have to cut services, increases taxes and make the rest of the country suffer harder because those who should be paying the most taxes sneak out of their moral obligations by using loopholes they know were never intended to there in the first place."

    Shame on you Google and shame on the Governments for letting this happen in the first place.

    Just because a loophole exists doesn't mean it is morally right or justifiable; especially when you yearly profits are already so obscene!

    1. Danny 14


      I would start designing new loopholes to attract big companies moving their money through our systems. Make it so they need a few offices with minimum workers. That way 2% of $lots is better than nothing.

  30. Stratman


    One day the legislators will realise that a book three inches thick, with twenty thousand tax rules is also a book three inches thick with twenty thousand tax loopholes*

    Do away with all tax exemptions and allowances, and watch your personal tax rate rate drop towards the floor.

    *Maybe they do realise it, but their law and accounting companies do very nicely out of the current mess, thank you very much.

  31. Graham Marsden

    I'm sure it's easy to find out how to do this...

    ... just Google for the information!

  32. Anonymous Coward
    Gates Horns

    Just how difficult is it...?

    to setup a company in a foreign country

  33. Yet Another Anonymous coward Silver badge

    @Makes you feel better about downloading

    You mean like where they claimed that LotR made a loss so they didn't need to pay Peter Jackson?

    Or how they sold the DVD rights to Spiderman to their own company for $1 and paid Stan Lee a percentage of $1.

    Or my favorite, where they didn't pay the author of Forest Gump, because it made a loss, then went back to him to write the sequel. He refused saying he couldn't let them waste any more money.

  34. johnvile
    Thumb Down


    This is a monstrous act of evil.

  35. Anonymous Coward
    Anonymous Coward

    Swings and roundabouts?

    The Bloomberg article says that "Google now has a stock market value of $194.2 billion", and that "if the company paid taxes at the 35 percent rate on all its earnings, its share price might be reduced by about $100" (from a current price of $607.98. )

    How much Capital Gains tax has the US government collected from the trade in shares of Google stock in the last few years, and how much less would they have made if the stock price was lower, because Google paid more corporate taxes?

    (I have no idea, and I'm not particularly comfortable with the notion that the tax on profits made from speculating on share prices is less than the tax on earnings from actually doing productive work, but it's an aspect of the system that shouldn't be ignored).

  36. Anonymous Coward
    Anonymous Coward

    Does anyone know if Dell Corp does this ?

    Does any one know what percentage of Dell's business if from sales outside the U.S., and where that info is published ?

  37. Yet Another Anonymous coward Silver badge

    @Does anyone know if Dell Corp does this

    It certainly does something like this in Europe. It's registered in Eire and allegedly makes a loss on every computer it sells elsewhere in europe. The germans were quite annoyed

  38. This post has been deleted by its author

  39. skeptical i

    Illegal? Nope. Unethical? Probably. Required by law? Yep.

    Sad fact of U.S. corporate law: Publicly- held corporations are required *by law* to return the highest possible return to their stockholders. If by some whack miracle $some_company actually wants to do the right thing (e.g., keep jobs in the U.S. at real wages, procure only recycled or cleanly produced goods, or whatever), it would risk stockholders' crabbing about "that costs too much, we're losing dividends, send the jobs to China". It's possible that the corporation might get some slack if it has a mission statement declaring its intent to do the right thing and investors be aware, but I don't know for sure.

    As was stated before, if our gubmint (and by this I mean the Congresscritters who slop with gusto at the trough of corporate campaign contributions) did not like the current system, changes would be made.

  40. Anonymous Coward
    Anonymous Coward

    The problem is...

    that the politician who ignores said loopholes gets generous donations from those benefiting from the loophole, whereas the "honest" politician doesn't.

    And how many television adds/mailout campaigns/newspaper adverts does "honesty" buy you?

    I don't know about you guys n girls, but where I come from a politician without cash to spend doesn't get (re)elected.

    As Leonard Cohen sang, "the poor stay poor and the rich get rich".

  41. Anonymous Coward

    Remember a thing called "Employee Benficiary Trusts?"

    UK citizens could decide how much if any tax that they paid.

    Hopefully, this Avoidsnce scheme with eventually be closed, I pay no UK VAT on my Google adword bills.

    Along with things like "Container Accounting" these loopholes are not ethical.

    What we really need is some form of "Golden Rule" where by if the inherent substance of these transactions is to avoid tax, then it is evasion, and the legal wording is subserviant to this "Golden Rule."

    The average "man on the street" has no idea what goes on, as for the Schemes used by some footballers, they're just as bad.

    Spoken as a past tax accountant.

  42. blackworx
    Dead Vulture


    "Google has its faults, but making use of a legal tax loophole isn't one of them"

    You trollin'?

    Seems like a pretty fcuking big fault to me.

  43. Anonymous Coward
    Anonymous Coward

    Name a US tech firm that DOESN'T do this.....

    ...Or keep it's IP off-shore in the Caribbean for legal/tax reasons.

  44. Anonymous Coward

    Being Legal is not the same and not being Evil

    Of course, the whole reason the Irish, Bermuda and EU tax systems are the way they are is precisely to get companies to put holdings in their locations.

  45. JaitcH

    Only international companies can do this easily (and some people)

    Another trick is for a mother company to bill a subsidiary for services supplied so the subsidiary never makes a taxable profit. Unfortunately, for these financial rip artists, governments are catching on and gaining more taxes in the process.

    The US Congress is bought off by Wall Street and companies so this will not change for a long time.

  46. citizen.joan

    Goodbye Google

    Hello Bing........Goodbye Googel. Yes, msft knows how to use the tax code, but they paid a higher rate in US taxes and gates has donated billion to charity.

  47. Cam 2

    Not evil

    It's really the mildest evil I can think of. Anyone in their right mind would do whatever they could to minimise their losses to 'the man'

    Google are known for their engineering successes, so it shouldn't be a surprise that they have built a highly efficient large scale scheme for processing their income. And, if the governments ever figure out exactly how to thwart this, the scheme will probably be replaced by something even more bizarre and inexplicable.

    1. Anonymous Coward

      Re: Not evil

      "And, if the governments ever figure out exactly how to thwart this, the scheme will probably be replaced by something even more bizarre and inexplicable."

      I'm sure there are a bunch of government people who are quite happy about this. Where, after all, does the money for the kickbacks come from? Sadly, these people then go on to lobby for corporations at every level - local, national, European Commission - saying that some paid-for legislation must be passed because it stimulates the economy, creates jobs, "fosters innovation", and all the other bullshit that just funnels cash to a bunch of very rich people while the politicians pretend that they're visionaries and their offshore accounts get topped up.

      Not evil, my bottom!

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