Oireachtas Joint and Select Committees

Tuesday, 23 July 2013

Committee on Finance, Public Expenditure and Reform: Joint Sub-Committee on Global Corporate Taxation

Global Taxation Architecture: Discussion with Director of the OECD Centre for Tax Policy and Administration

2:00 pm

Photo of Richard Boyd BarrettRichard Boyd Barrett (Dún Laoghaire, People Before Profit Alliance) | Oireachtas source

Yes; it is double Dutch. The only explanation Mr. Saint-Amans seems to be giving is that our low corporate tax rate seems to attract companies involved in this aggressive tax avoidance. For the benefit of people trying to understand this situation, is the following brief description, given to me by former Google workers, an accurate description of how Ireland functions as a facilitator of tax avoidance?


Google's advertising is a digital product. They sell that product to customers in Europe, the Middle East, and Africa from their Dublin HQ - and as such don't have to pay taxes on that anywhere except Ireland because the sale of that good is deemed under international law to have taken place in Ireland.

The profit they make from all those advertising sales is eaten up by a charge levied by Google Ireland Limited's holding company - which (conveniently) tends to be almost the exact amount of profit they make. The little bit that is left is charged at the standard 12.5%.

The holding company's profits aren't taxed because of Irish law waiving corporation tax on certain profits made from intellectual property royalties and/or because the company isn't managed or controlled in Ireland. That money then tends to be routed through further subsidiaries in Holland before moving to the Caribbean.
Is that a fairly accurate description of the double Irish?

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