Report: Google moves tax status of Bermuda holding company – The Royal Gazette

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Updated: April 21, 2021 at 8:42 AM

Simplifying Structure: Google has been criticized for its tax provisions and sending billions of dollars in revenue to companies in Bermuda. It has now been reported that a holding company which was a tax resident of Bermuda is now a tax resident of Ireland (file photo)

Google has moved the tax residence of Google Ireland Holdings Unlimited Company from Bermuda to Ireland, according to a report.

It has also stopped conceding its intellectual property in Bermuda, and is now doing so in the United States, as it has indicated it will do in 2019 to simplify its corporate structure.

The changes are mentioned in Irish weather, who reported that the tech giant used a controversial tax arrangement known as the “Double Irish” to transfer more than $ 75.4 billion out of Ireland in 2019.

This tax regime was abolished for new businesses in 2015, but was allowed for those already using it until the end of last year, when it was phased out.

Google has been criticized in the past for tax provisions that have allowed it to lower its foreign tax bill.

In 2016, several British newspapers put Bermuda in the spotlight regarding the billions of dollars sent to the island by Google. At the time, the company licensed intellectual property in Bermuda.

The sun on sunday pointed out how Google directs billions of dollars in profits a year to the island, and noted that the company’s only physical presence in Bermuda was a PO box, numbered 666, located at the Hamilton General Post Office. The newspaper explained how Google Bermuda Unlimited and Google Ireland Holdings were registered at the address of the law firm Conyers Dill and Pearman on Church Street.

In 2019, Reuters reported that a Google spokesperson confirmed it would abandon the licensing structure, saying it was in line with international rules and followed changes in US tax law in 2017.

Saturday, Irish weather reported that Google had used the Irish double taxation scheme in 2019. It also released a statement from Google, which said: “In December 2019, in line with the OECD findings on base erosion and the profit shifting and changes to US and Irish tax laws, we have simplified our business structure and started licensing our intellectual property in the US, not Bermuda. Accounts filed today cover l ‘fiscal year 2019, before we made these changes.

“Including all annual and one-time income taxes over the past ten years, our global effective tax rate has been over 20 percent, with over 80 percent of that tax owed to the United States. “

At week-end, Irish weather reported that, according to company accounts, until the end of 2019, Google Ireland Holdings Unlimited Company was an IP licensing company with no reported employees and was tax resident in Bermuda, but became tax resident in Ireland January 1, 2021.

The Royal Gazette has contacted Google regarding the reported changes to its IP licenses and Google Ireland Holdings Unlimited Company, and is awaiting a response.


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