Google indicates belief Irish tax affairs in order

Internet giant Google has given the clearest indication yet that it believes its Irish tax affairs are in order.

Internet giant Google has given the clearest indication yet that it believes its Irish tax affairs are in order.

In a filing with United States regulatory authorities, the company says it has "not accrued any penalties related to our uncertain tax positions as we believe that it is more likely than not that there not be any assessment of penalties".

The note attached to Google's consolidated financial statements for 2007, which have just been lodged with the US Securities and Exchange Commission (SEC), says that its 2002 to 2007 tax years, "remain subject to examination by the appropriate governmental agencies for Irish tax purposes".

It is not clear whether the Revenue Commissioners are actively investigating Google or if they merely retain the right to do so.

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While many of the statements in SEC filings are standard warnings to prevent any potential legal action by shareholders, the Google statements regarding tax are stronger than those made by other multinationals based in Ireland.

At 12.5 per cent, Ireland's corporation tax rate is half the rate that applies in the US, with the result that many US multinationals reduce their "effective tax rate" by booking more profits through their Irish subsidiaries.

In 2006, the US Internal Revenue Service (IRS) negotiated a deal with Google that limited the tax savings it can make via its Irish subsidiaries.

Last night, a spokesman for the company declined to comment "above and beyond" the information in the filing.

Google's Irish operations in Dublin, which support customers in Europe, the Middle East and Africa, currently employ more than 1,500 staff.

The document also reveals that Google is appealing an audit by the US tax authorities of its 2003 and 2004 tax years. Google says it is appealing "certain issues" relating to the IRS audit but that it has made satisfactory allowance in its accounts for "any adverse results" of the appeal.

Google also says there are "various other ongoing audits" in other countries in which it operates but that these are "not material" to its financial statements.

The most recent filed accounts for Google Ireland Limited, its main operational company in Ireland, show that it paid €3.3 million in Irish tax in 2006. It had a turnover of €3.3 billion and made a profit of €17.3 million.

Google Ireland is a subsidiary of an unlimited company called Google Ireland Holdings, which is owned by Google Inc, the US parent, via an intermediary in the Bahamas.