FREE: Google’s valuation of intangibles under audit

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

FREE: Google’s valuation of intangibles under audit

Google is under audit in the US following reports it uses transfer pricing to reduce its overseas effective tax rate down to just 2.4%.

The Internal Revenue Service (IRS) is investigating how Google values software rights, and other intellectual property (IP), owned by its offshore Irish subsidiary.

The audit follows reports last year that Google pays an overseas tax rate of 2.4% (compared to the corporate tax rate of 12.5% in Ireland) and a company-wide tax rate of 22.2% (the US rate is 35%) by using double-Irish and Dutch sandwich structures to limit the tax due on its IP.

According to Bloomberg, Google is now under audit for these actions and the inquiry is focusing on the financial arrangements other Google subsidiaries - YouTube, Postini and DoubleClick - have made with Google Ireland to pay for access to the IP.

Google maintains the investigation by the IRS is routine.

more across site & shared bottom lb ros

More from across our site

New hires from rivals are reportedly being axed from the firm, following a steep decline in profits
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
Firms announced tax hires and promotions across Europe and the US, while fresh figures from Ireland showed corporation tax receipts edging down in the first quarter
The country has overseen better audit procedures and demonstrated commitment to acting as a 'regional leader' on international tax matters, the OECD said
Barrister Setu Kamal and policy guru Dan Neidle have clashed over the former’s legal action against Google, described as ‘bonkers’ by Neidle
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Dual-qualified corporate tax specialist Christoph Schimmer joins the firm after stints at Deloitte, Cerha Hempel and DLA Piper
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
LED Taxand’s partner tells ITR about entrepreneurial inspirations, the importance of people skills, and what makes tax cool
Shiny new offices like Ryan’s in London Bridge aren’t just a cost – they signal that a firm is willing to align with its clients’ interests
Gift this article