Google, denies pm evaded taxes of 98 million taxable – The Messenger

The Milan prosecutor’s office has pulled the investigation row today regarding Google, the world of information technology giant, accused, according to the calculations of the Tax Unit of the Guardia di Finanza, the Italian tax authorities embezzling, between 2009 and 2013 taxable income for about 227 million euro, thanks to an elusive scheme involving a number of companies located in Ireland, the Netherlands and Bermuda. The prosecutor Isidoro Palma, owner of the investigation, has closed the investigation, in view of the indictment of five managers, all foreigners (two Irish, one English, the Mountain View team an American and a Taiwanese citizen) , to which, however, was able to challenge, as a criminal act, only one non-payment of IRES, the tax on corporate income, on a taxable income of 98.2 million euro.

disputing this, it is therefore much lower than that emerged from ascertainment tax of yellow flame. The charge is non-payment of taxes by creating “a stable occult organization” based in Italy but made appear as Irish. therefore risk the process John Thomas Herlihy, Graham Law, Aubyn Ronan Harris, John Kent Walker Jr. and Daniel Lawrence Martinelli, all ‘transition through the boards of directors of both companies at the center of the investigation, Google Italy and Google Ireland, where they have served as the legal representative or the president, with the responsibility of signing the financial statements. The power of attorney, in the act notified this morning, has reconstructed the scheme that would use Google Italy to lower its tax burden: the Italian company, should figure despite having a preparatory and auxiliary task of commercial real, actually he had a role operational and, therefore, would have concluded contracts for the sale of advertising space on the web.

But, instead of invoice them as Google Italy, were recorded by the subsidiary based in Dublin. In this way they were produced in Italy revenues to 1.19 billion Euros between 2009 and 2013. Of these, 656 million euro were then shot, by way of royalties, the Google Netherland Hodings, a Dutch company ” no employees and organizational structure “that poured them almost entirely to a third company, Google Ireland Holdings (different from that investigated),” company incorporated in Ireland but tax resident “in Bermuda, known tax haven. The criminal investigation figures, however, are different from those found by the Guardia di Finanza. Act signed by prosecutor Palma, in fact, refers to 98.2 million euro of taxable IRES (tax on business income) not declared during that five-year period, and not to the 227 million of yellow flame. An amount which would result in a tax evasion of around 27 million euro if the effective tax rate to be paid was equal to the theoretical rate of 27.5 percent.

The GDF had included in its calculations the amounts which would have been withheld at the level of the Irap and never paid by the Italian branch as an advance on royalties, which are not returned in the criminal complaint but that will only be the subject of any negotiations with the Inland revenue. Italy disputed the figures are much lower than those charged to the giant in France, where the tax authorities across the Alps would ask the subsidiary based in Paris 1,6 billion euro.