December 10, 2012

Double Irish, Dutch Sandwich Corporate Tax Strategy


Double Irish, Dutch Sandwich corporate tax strategy.
 
Bloomberg on Google’s corporate tax strategy 
By legally funneling profits from overseas subsidiaries into Bermuda, which doesn’t have a corporate income tax, Google cut its overall tax rate almost in half. The amount moved to Bermuda is equivalent to about 80 percent of Google’s total pretax profit in 2011.

The Double Irish, Dutch Sandwich strategy 
Multinational companies cut their tax bills using “transfer pricing,” paper transactions among corporate subsidiaries that allow for allocating income to tax havens and expenses to higher-tax countries.

In Google’s case, an Irish subsidiary collects revenues from ads sold in countries like the U.K. and France. That Irish unit in turn pays royalties to another Irish subsidiary, whose legal residence for tax purposes is in Bermuda.

The pair of Irish units gives rise to the nickname “Double Irish.” To avoid an Irish withholding tax, Google channeled the payments to Bermuda through a subsidiary in the Netherlands -- thus the “Dutch Sandwich” label. The Netherlands subsidiary has no employees.

The Dutch unit’s payments to the Bermuda entity last year were up 81 percent to $9.8 billion from $5.4 billion in 2008. Google’s overseas sales have increased at about the same rate.

Higher tax rates lead to lower tax revenues for countries.


Tags: tax strategy, double irish tax strategy, dutch sandwich tax strategy, google corporate tax strategy, reducing corporate tax