This is how the Google system works: All earnings achieved in Europe are posted to Google Ireland Ltd., headquartered in the Irish capital Dublin. German fiscal authorities have no access to these revenues and profits, because the company does not maintain any places of business in the classic sense in Germany.
Google Ireland reported revenues of €10.1 billion in 2010, but they were almost completely consumed by advertising expenses and personnel costs for the company's 2,000 employees. The largest expense, about €7.2 billion, consisted of licensing fees that Google Ireland paid to another Google subsidiary in the Netherlands. In this manner, almost all of the income was sucked away from Dublin. The Irish state was left with only €16.8 million in revenues subject to corporate income tax, as well as the taxes on employee wages.
Google Netherlands Holdings B.V. in Amsterdam, which collected the licensing fees from Dublin, is a company without employees. It paid only €2.7 million in corporate income tax in the Netherlands. That's because the Dutch company funneled the lion's share of its revenues from Ireland back to the Emerald Isle, in the form of a licensing fee to Google Ireland Holdings.
The Bermuda Treasure Chest
Shuffling billions back and forth may seem absurd to the uninitiated, but it's worthwhile. Google Ireland Holdings is in fact domiciled in two places. It was established under Irish law, but its administrative headquarters are in Bermuda. The benefit for Google is that there's no corporate income tax in Bermuda.
The operation is complicated, but it's extremely lucrative. It allows Google to move its earnings, which consist mainly of advertising revenues, out of Europe while paying almost no taxes there, depositing them in a tax haven to which the US Treasury has no access. The US authorities would be able to tax these earnings only if they were later distributed to the US parent company, but that seems unlikely at this point. Google has amassed some $24.8 billion in largely tax-free income in its Bermuda treasure chest..........
Belgium, for example, has one of the highest corporate income tax rates in the world: 33.99 percent. In practice, however, the debt-ridden country collects far less from companies, thanks to loopholes in its tax laws. The average tax burden of the 50 most ingenious companies, with total earnings of €27 billion in 2010, was a paltry 1.04 percent.