Newly filed Google Ireland Holdings accounts show $75B+ in profits moved through the subsidiary in 2019, the last year Google used the “double Irish” tax scheme
Newly filed accounts show that over $75bn in profits moved through a subsidiary of Google that was incorporated in Ireland in 2019 …
Context & Ripple Effects
The 2019 accounts are the closing entry on a structure Bloomberg had been tracking for years: filings showed $19.2B routed to a Bermuda shell company in 2016 alone, moving through Irish firms and a staffless Dutch entity. The scheme had survived legal challenge — Google beat France's $1.3B bill in 2017 when a court ruled Google Ireland Limited wasn't subject to French corporate and VAT taxes for 2005-2010 — but 2019 was the last year it operated.
What makes the filing more than an archive is what followed: Google Ireland later agreed to a €345.2M tax settlement with Irish authorities on top of a €218M backdated payment, and Facebook had already closed its Irish subsidiary and repatriated billions after an IRS suit. The double Irish isn't just ending; the unwind is generating real tax bills in both Dublin and Washington.
First-order effects
- Google had to restructure its Irish profit-routing entirely after 2019, ending the Irish-Dutch-Bermuda conduit that moved $75B+ through Google Ireland Holdings in its final year.
- Irish authorities moved from hosting the structure to collecting from its aftermath, with Google Ireland's €218M backdated payment and €345.2M settlement marking the first direct tax costs of the unwind.
Second-order effects
- Facebook's earlier closure of its Irish subsidiary under IRS pressure set the template Google's unwind now follows, suggesting US tax enforcement — not Irish policy — is the binding constraint on offshore structures.
- Ireland's value proposition shifts from zero-tax conduit to a jurisdiction where multinationals actually book and pay tax on large revenue bases — Google Ireland's revenue grew from €45.7B in 2019 to €48.4B in 2020 even as the scheme ended.
Third-order effects
- If the Facebook and Google unwind patterns hold, the era of routing global digital profits through staffless offshore entities closes structurally, with profits taxed where enforcement reaches — the US and operating jurisdictions — rather than in Bermuda.
- Ireland's FDI model faces a repositioning: the conduit role that made it a profit waypoint for US tech gives way to a real-operations role, changing what kind of corporate presence the country attracts.
The trend: US multinationals are dismantling Irish-Bermuda profit-shifting structures under tax-authority pressure, converting offshore conduits into onshore taxable operations.