Mr. Pascal Saint-Amans:

It is a description of the Google operation. I have no comment on the operations of private companies because I do not necessarily know them. Does this result in having large profits located in no-tax jurisdictions? The answer is yes, and this is why we are pushing for the best project. When I said the double Irish exists because Ireland is attractive with the 12.5% tax rate, we need to understand how it works. This is related to the way the US articulates Subpart F with check-the-box rules. Companies will locate real activity in Ireland for the 12.5% rate and then create all these chains of entities under the check-the-box rules, which will allow them to shift the profits, using international tax rules such as transfer pricing, to no-tax jurisdictions. Thus they avoid taxation in both the US and Ireland at 12.5%. That is the overall picture, which explains why the double Irish is now known in the world.