Google lowered 2015 taxes by $3.6 bn using ‘Dutch Sandwich’

Alphabet Inc.’s Google saved $3.6 billion in worldwide taxes in 2015 by moving 14.9 billion euros ($15.5 billion) to a Bermuda shell company, new regulatory filings in the Netherlands reveal.

The amount the company shifted through its Dutch subsidiary, Google Netherlands Holdings BV, and then on to a Bermuda mailbox, was 40 percent greater than in 2014, according to filings the company made with the Dutch Chamber of Commerce on Dec. 12 and which were made available online Tuesday. News of the filings was first reported by the Dutch newspaper Het Financieele Dagblad.

Alphabet moves the bulk of its non-U.S. profits through this Dutch subsidiary, which has no employees. The company has used the Netherlands company since 2004 as part of a tax structure dubbed a "Double Irish" and a "Dutch sandwich." By moving most of its international profits to Bermuda, the company was able to reduce its effective tax rate outside the U.S. to 6.4 percent in 2015, according to Alphabet’s filings with the U.S. Securities and Exchange Commission.

“Google complies with the tax laws in every country where we operate," a Google spokesman said in a statement. In February, Google also said that such calculations of an effective tax rate do not reflect the methods actually used to determine its international taxes in any jurisdiction.

Some 12 billion euros of the money funneled through the Dutch company in 2015 came from Google Ireland Limited, which collects most of Google’s international advertising revenues. The rest came from a Google subsidiary in Singapore that serves a similar role. The Dutch company then transfers this money on to Google Ireland Holdings Unlimited, which has the right to license Google’s intellectual property outside the U.S. That company is based in Bermuda, which has no corporate income tax. The use of the two Irish entities is what gives the structure its "Double Irish" moniker.