Google’s parent company, Alphabet, has announced a restructure which will see the end of its intellectual property licensing scheme, often referred to as the ‘double Irish, Dutch sandwich’, which uses Irish and Dutch subsidiaries to shift profits away from the US and to a large extent from the EU.
According to Reuters, filings by Alphabet in the Netherlands indicate the ending of these arrangements ‘as of 31 December 2019 or during 2020’.
The change has been brought about by a combination of Ireland’s decision in 2014 to phase out the ‘double Irish’ structure under which Irish companies were permitted to hold tax residence in low- or no-tax jurisdictions, and the US Tax Cuts and Jobs Act, which since January 2018 has enabled US companies to repatriate profits taxed overseas without suffering further US taxation.
Google’s parent company, Alphabet, has announced a restructure which will see the end of its intellectual property licensing scheme, often referred to as the ‘double Irish, Dutch sandwich’, which uses Irish and Dutch subsidiaries to shift profits away from the US and to a large extent from the EU.
According to Reuters, filings by Alphabet in the Netherlands indicate the ending of these arrangements ‘as of 31 December 2019 or during 2020’.
The change has been brought about by a combination of Ireland’s decision in 2014 to phase out the ‘double Irish’ structure under which Irish companies were permitted to hold tax residence in low- or no-tax jurisdictions, and the US Tax Cuts and Jobs Act, which since January 2018 has enabled US companies to repatriate profits taxed overseas without suffering further US taxation.
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