04 Dec Google is still using the Double Irish with Bermuda
At a hearing held in the European Parliament on 28 November 2018, Google’s Head of Economic Policy for Europe, the Middle East and Africa, Adam Cohen, confirmed that Google is continuing to use the Double Irish structure through an Irish-registered subsidiary, Google Ireland Holdings, in Bermuda.
The Irish government announced the phase-out of the Double Irish in 2014 but gave companies using such a structure until 2020 to create an alternative structure. The last public confirmation that Google was continuing to use the Double Irish came in 2016.
Google’s representative Mr Cohen confirmed the use of the Double Irish in comments he made in response Irish MEP Matt Carthy, who questioned him in a hearing of the TAX3 special committee on financial crimes, tax evasion and tax avoidance in Brussels.
“The latest annual tax return filed by Google Ireland Holdings with the Companies Register in Dublin seems to show that Google’s Double Irish structure with Bermuda remains in place, and I questioned Google’s representative as to whether this was the case at our hearing,” Mr Carthy said.
“Mr Cohen confirmed that Google’s corporate structure has not changed in the past several years. The response from Google’s representative today is significant because it dispels two myths we hear repeatedly.
“The first myth is that the Double Irish is gone. The Fine Gael government keeps referring to this scam as something in the past, but a company like Google is continuing to avoid billions in tax on an annual basis due to its ongoing use of the Double Irish structure. It is doing this by storing its intellectual property in an Irish-registered letterbox company that supposedly has its ‘management and control’ located in zero-tax Bermuda.”
In 2016, Vice President of Google Inc (now Alphabet) Tom Hutchinson told the British Parliament’s Public Accounts Committee that Google did not have a single employee in Bermuda.
“The second myth these comments dispel is that the recent US tax reforms, including the Tax Cuts and Jobs Act (TCJA) 2017, have removed the incentive for US multinationals to store their intellectual property offshore. If this is the case, then surely Google would have made a change to its corporate structure to end the situation where most of its IP is held in Bermuda.
“This follows reports of other US multinationals telling their shareholders that, apart from the once-off tax charge in 2017 imposed under the TCJA, they do not expect the tax reform to affect their effective global tax rate, or else that it could actually lower it.
“It is unjustifiable that Google can continue to use this structure for two more years. Just how many billions of euros will Google have shifted to Bermuda since 2014 when the announcement was made to end the Double Irish. Clearly, tax reform in the US has not ended the motivation for multinationals to base their IP in tax havens, with the Irish government’s help.”