Google Establishes "Double Irish, Dutch Sandwich" Tax Avoidance Structure

By 2003, Google had established the “Double Irish with a Dutch Sandwich”—the most sophisticated corporate tax avoidance structure in history—allowing the company to route profits through Ireland, Netherlands, and Bermuda to avoid paying billions in taxes on non-US revenues despite “Don’t be evil” motto.

The Structure

The Double Irish Dutch Sandwich required three subsidiaries and exploited gaps in tax treaties:

Entity 1: Irish Operating Company (Ireland-resident)

• Held licenses to use Google intellectual property
• Received all non-US advertising revenues
• Employed actual workers in Ireland
• Paid substantial royalties to Dutch entity for IP usage

Entity 2: Dutch Shell Company (Netherlands)

• Pure intermediary with minimal actual operations
• Received royalties from Irish operating company
• Immediately passed payments to Bermuda entity
• Existed solely to avoid withholding taxes

Entity 3: Irish-Bermuda Company (Bermuda-resident, Irish-incorporated)

• Owned Google’s non-US intellectual property rights
• Tax-resident in Bermuda (0% corporate tax)
• Incorporated in Ireland (to access tax treaties)
• Received royalties from Dutch entity tax-free

How the Money Flowed

Step 1: Google search ad revenue from Europe, Asia, etc. goes to Irish operating company Step 2: Irish company pays ~90% of revenue as “royalties” to Dutch entity for IP use Step 3: Dutch entity immediately transfers money to Bermuda entity Step 4: Profits accumulate in Bermuda with 0% tax Result: Google paid <3% effective tax on non-US profits

The Tax Arbitrage

Without structure: ~35% US corporate tax + 12.5-25% foreign taxes = ~45% total With structure: ~2.4% effective tax rate on foreign profits

Example on $10 billion foreign revenue:

• Without scheme: $4.5 billion in taxes
• With scheme: $240 million in taxes
• Tax savings: $4.26 billion in one year

Why Each Jurisdiction?

Ireland: The Hub

• 12.5% corporate tax rate (low but not zero)
• Tax treaties with most countries preventing withholding taxes
• Lax residency rules allowing Irish-incorporated companies to be tax-resident elsewhere
• EU membership providing legitimacy and treaty benefits
• Encouraged tech companies to establish European headquarters there

Google’s Irish operating company employed thousands in Dublin—creating real presence to justify profit allocation.

Netherlands: The Conduit

• No withholding tax on royalty payments to other EU countries (due to EU directives)
• Extensive tax treaty network preventing withholding taxes
• Facilitated profit shifting between Ireland and Bermuda without tax leakage

The Dutch entity had minimal operations—often just a brass plate office—but was essential to avoid withholding taxes.

Bermuda: The Destination

• Zero corporate income tax
• Zero withholding taxes
• Financial secrecy preventing transparency
• No substance requirements (could be pure shell company)

Google’s Bermuda entity owned the valuable non-US IP rights worth tens of billions but paid no taxes on royalties received.

The Intellectual Property Manipulation

The scheme’s foundation was IP rights allocation:

Setup: Google “sold” or “licensed” non-US intellectual property rights (search algorithms, ad tech, software) to the Bermuda subsidiary

Justification: Claimed IP was developed globally, not just in US, so foreign rights belonged to foreign entity

Reality: Most innovation happened at Google’s California headquarters—the IP transfer was pure tax avoidance

Value manipulation: Google underpriced the IP transfer to minimize US taxes on the sale, then collected massive royalties in Bermuda

Scale of Tax Avoidance

Google’s Double Irish structure shielded enormous profits:

2011: ~$10 billion shifted through Dutch entity to Bermuda 2015: $15.5 billion shifted 2017: $19.9 billion shifted (€19.9 billion in one year) 2018: $24.5 billion shifted

Cumulative 2003-2019: Over $200 billion in profits routed through tax havens

Tax avoided: Estimated $30-50 billion in cumulative taxes from 2003-2019

Other Tech Companies Following Google’s Lead

Google’s success inspired industry-wide tax avoidance:

Apple: Used Double Irish for ~$100B+ offshore Facebook: Adopted similar structures Microsoft: Offshore structures avoided billions Amazon: Luxembourg-based tax schemes

By 2010, the Double Irish was shielding over $100 billion annually in US multinational profits from taxation—the largest tax avoidance scheme in history.

How Ireland Benefited

Ireland deliberately designed tax rules to attract tech companies:

Direct benefits:

• Employment: Google employed 8,000+ in Ireland
• Economic activity: Real operations in Dublin
• Legitimacy: EU member hosting US tech giants

Indirect benefits:

• Tax revenue: Ireland still collected some taxes (even at 2% on billions)
• Economic multiplier: Tech workers spend money in Irish economy
• Status: Became European tech hub

The bargain: Ireland traded global tax base for local economic benefits—essentially helping multinationals avoid taxes owed elsewhere.

The “Don’t Be Evil” Hypocrisy

Google established Double Irish structure same year as publicizing “Don’t be evil” motto (2004 IPO letter).

The contradiction:

• Claimed: “We believe in doing good things for the world”
• Reality: Avoided tens of billions in taxes that fund schools, infrastructure, healthcare

Google’s tax avoidance directly reduced funding for public services in countries where it earned profits—hardly “doing good for the world.”

International Pressure and End of Scheme

2013: Senate investigations exposed scale of tech tax avoidance 2014: Ireland announced phase-out of Double Irish (effective 2020) 2015: EU investigations into Irish tax rulings 2017: Trump tax reform reduced incentives for offshore profit shifting 2019: Google announced end of Double Irish structure 2020: Structure officially closed (replaced with other schemes)

The Cover-Up: Maintaining Secrecy

Google fought to keep tax structure secret:

Minimal disclosure: Annual reports provided almost no detail on tax structure Complex subsidiaries: Dozens of entities obscured money flows Fought transparency: Opposed country-by-country tax reporting Lobbied against reform: Spent millions lobbying to preserve tax advantages

Only investigative journalism (Bloomberg, Guardian) and Senate investigations revealed the full scope.

Google’s Defense

When confronted, Google claimed:

“We comply with tax law”: Technically true but ethically bankrupt—exploiting loopholes is legal but socially harmful

“We pay all taxes owed”: Misleading—structure was designed to minimize what was “owed”

“We create jobs in Ireland”: True but irrelevant—jobs don’t justify avoiding taxes elsewhere

“Other companies do it too”: Admission that tax avoidance is industry-wide, not justification

Social Harm from Tax Avoidance

Google’s $30-50 billion in avoided taxes represented:

Lost public investment:

• Schools underfunded
• Infrastructure crumbling
• Healthcare systems strained
• Research budgets cut

Inequality exacerbation:

• Working people pay full taxes
• Corporations avoid obligations
• Wealth concentrates in shareholder hands

Race to bottom:

• Countries compete to offer lowest taxes
• Global tax base erodes
• Public services deteriorate

Significance

The Double Irish Dutch Sandwich represented:

Largest tax avoidance scheme in history: Over $100B annually shielded by 2010

Template for tech industry: Google’s structure copied across sector

Regulatory failure: Required cooperation of multiple jurisdictions enabling evasion

Wealth concentration mechanism: Avoided taxes became shareholder profits

Corporate hypocrisy: Company promising ethics pioneered massive tax avoidance

Google’s tax scheme demonstrated that even companies claiming ethical values will aggressively avoid taxes when profitable—establishing that regulation, not voluntary compliance, is necessary to ensure corporations pay fair share.

The structure’s eventual closure in 2020 didn’t end Google’s tax avoidance—it simply forced evolution to new schemes exploiting different loopholes, showing that tax justice requires fundamental reform, not just closing individual loopholes.