Google alters Irish structure

Google, the internet search engine giant, has prepared the ground to move assets from its main Irish holding company into other parts of its empire, according to new official filings.

Records in the Companies Office show that the group has introduced sweeping changings to the internal rules of a vehicle called Google Ireland Holdings, which empower it to transfer virtually any class of asset free of charge to any other Google subsidiary. The change was executed by way of an amendment to the articles of association of the holding company.

The amendment, which was notified in February, was made last December. That same month, Google struck a deal with the US tax authorities to limit the tax savings it makes in Ireland.

Google Ireland Holdings, which declared royalty income approaching €400 million in its last public accounts, plays a prime role in its Irish tax structure.

However, Google's agreement with the US Internal Revenue Service will slow or halt a decline in its global effective tax rate, through which it saves tens of millions of euro by routing a large part of its international profits through Dublin.

Google declined to discuss its tax affairs and it would not say whether it now plans to transfer assets from Google Ireland Holdings. "We don't have any further comment to make on our tax structure except to say that all Google companies are fully tax compliant.

"We don't comment on speculation around what we may or may not do in the future."

The scale of the assets currently held by the holding vehicle is not publicly known as Google took out unlimited liability status for it in 2006. Such companies do not file public accounts.

There is no limit on the assets that can be moved from the company to any other Google entity.