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

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

Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals
Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses
Gift this article