Strategy of double Irish with Dutch Sandwich is international tax evasion involving channelling profits first through Irish company, then Dutch company, then to Irish subsidiary in a location – like Bermuda —with lower or no income taxes
Tech giant Google shifted $22.7bn through a Dutch shell company to Bermuda in 2017, in a move that is known as ‘double Irish, Dutch sandwich’, as part of an arrangement that allows the American firm to reduce its foreign tax bill, according to documents filed at the Dutch chamber of commerce.
According to Reuters, the company used Google Netherlands Holdings BV to shift revenue on royalties earned outside of the US to Google Ireland Holdings in Bermuda, where there is no corporate income tax, the sum of money that was transferred through Google Netherlands Holdings BV was about $4.69bn more than in 2016, the documents showed.
For more than a decade the arrangement has allowed Google’s owner, Alphabet, to enjoy an effective tax rate in the single digits on its non-US profits, about a quarter of the average tax rate in its overseas markets.
The strategy of double Irish with a Dutch Sandwich is an international tax evasion strategy that involves channelling profits first through an Irish company, then through a Dutch company, and then to another Irish subsidiary headquartered in a location – like Bermuda —with lower or no income taxes. The method uses features of the various countries’ tax codes to dramatically reduce tax burdens.
In June, 949 non-financial American companies held $1.8tn overseas – a 9.5% decline from the end of 2017, according to a report from Moody’s Investors Services. However, Alphabet was among the companies with large international cash stockpiles – at $102.3bn as of the end of June.
“We pay all of the taxes due and comply with the tax laws in every country we operate in around the world,” Google said in a statement.
“Google, like other multinational companies, pays the vast majority of its corporate income tax in its home country, and we have paid a global effective tax rate of 26% over the last 10 years.” the company added.
Under pressure from the European Union and the United States, Ireland decided to phase out the arrangement, ending Google’s tax advantages in 2020. According to Reuters, Google Netherlands Holdings BV paid more than $3.8m in taxes on a profit of more than $15.5m in 2017.