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Who says they don't have activities in Ireland? A lot of Google's employees are actually based in Ireland. > Just because you can do something "in general", yo
by charlesdm 10y ago
Who says they don't have activities in Ireland? A lot of Google's employees are actually based in Ireland.
> Just because you can do something "in general", you can't do it with the specific purpose of circumventing another legal obligation.
Most countries have laws that say you can't do something JUST for tax purposes. You can, however, structure things in a tax friendly way, if there's a commercial motive to do so.
- ucaetano 10y agohttp://www.independent.ie/business/technology/google-hits-5000-employee-level-in-dublin-now-one-of-capitals-biggest-employers-31480103.html http://www.independent.ie/business/technology/google-hits-50... Over 5k employees apparently.
- charlesdm 10y agoIf that's not sufficient substance then I don't know what is. Yes, obviously they structured it like that intentionally and Ireland is happy with them being there. But it seems reasonable for a structure like that to fall within the scope of the law.
- soneil 10y agoFor comparison, the numbers I've seen for the Paris office are 2-300. It's a satellite office, not a headquarters.
- hvalika 10y ago^^^ exactly that. The rule is generally that your "principal purpose" can't be to avoid taxes (in this case). There is also the "economic substance doctrine" which actually codifies the above principle. Basically, you have to have a non-tax reason to do something -- even if the tax reasons are ridiculously great. There are certain things where you are allowed to write into the IRS and get a Private Letter Ruling. "Business Purpose" is not one of them.