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 2025

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

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%.

google150.jpg

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

Awards
Submit your nominations to this year's WIBL Americas Awards by January 23
Recent changes in UK tax rules and cross-border requirements are generating high demand for specialist advice, according to MHA
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood
Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
The new outfit, Ashurst Perkins Coie, will bring together around 3,000 lawyers across 23 countries
As World Tax unveils its much-anticipated rankings for 2026, we highlight the two Brazilian firms that had a standout year of tier promotions
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
Gift this article