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Google parent Alphabet is to stop using an intellectual property licensing loophole, known as the ‘Double Irish, Dutch sandwich’, which allowed it to cut its global tax bill, Reuters reports.
The strategy involves companies moving money from an Irish subsidiary to a Dutch holding company and then back to an Irish holding company located in Bermuda with licensing rights to Google intellectual property.
Because Bermuda has no corporate income tax it was lucrative for Google to report income there, effectively delaying tax payment on international earnings to the US for years while paying a lower tax rate in Europe.
After pressure from the EU and the US Ireland closed the loopholes in 2014 and companies were given until 2020 to comply with new tax regulations.
Dutch filings at the Chamber of Commerce and seen by Reuters showed that in 2018 Google moved €21.8bn through its Dutch holding company to Bermuda, up from €19.9bn in 2017.
Reuters said the filing did not give a definite end date but that Google management expected the termination to take place ‘as of 31 December 2019 or during 2020′.
The scheme was in place for over a decade and allowed the tech giant to cut its tax bill by hundreds of billions of euros, the Guardian estimates.
The Netherlands does not currently tax royalties, but is planning to change this as part of a package of measures to crack down on tax evasion in 2021.
Some 10,000 shell, or letter-box, companies are based in the Netherlands and are primarily used to shift corporate earnings and obscure ownership. Google has used its Dutch affiliate to move money since 2004.
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