How Google Kept $23 Billion in Bermuda, Legally… Until It Didn’t
Alphabet (Google’s parent company) ran a variation of the same Double Irish structure Apple used. In 2019, its Bermuda subsidiary reportedly held over $23 billion. By 2020, the structure was wound down.
Here’s what it did — and the small-scale ideas that still legally apply.
Last edited 12 August 2026 - Authors: Joe Hanson, FTR Director & Global Partner, with input and advice from FTR’s LATAM Tax Partners.
The Structure
Google (Alphabet) used its own version of the Double Irish for most of the 2003-2020 period - see our article here: ftr.finance/famous-cases/apple-double-irish
Non-US ad revenue flowed to Google Ireland Ltd, which paid royalties to Google Ireland Holdings — an Irish-incorporated entity tax-resident in Bermuda
Between 2011 and 2019, this holding company reportedly transferred over $75 billion through Bermuda’s zero-tax jurisdiction
The Numbers (Public Filings)
Reported figures suggest Google saved billions in annual tax through the arrangement. The Bermuda holding company was reportedly holding roughly $23 billion by 2017-2018. In 2019, Alphabet dissolved the arrangement in advance of Ireland’s grandfathering deadline.
Why Google Ended It
The same reasons Apple did: Ireland closed the base rule, EU pressure mounted, US tax reform (GILTI) reduced deferral value, and OECD BEPS/Pillar Two loomed. Continuing the structure post-2020 would have added compliance risk without meaningful ongoing benefit.
The Underlying Ideas — Still Valid at Small Scale
The legitimate ideas Google exploited, and which FTR clients can access:
Digital-services income has flexible geographic sourcing. Where you legitimately book revenue matters. This still applies to smaller SaaS and digital businesses.
IP location drives corporate tax exposure. Where your IP legally sits matters. For a SaaS founder, artist, or retail brand, IP holding structure choice is a genuine planning lever.
Personal residency of the beneficial owner matters most. Google’s US-parent status meant US tax always eventually applied. The founders’ personal US residency is why the structure only deferred (not eliminated) tax.
For an FTR client building a global online business, the small-scale lessons:
choose IP holding jurisdiction carefully (see Article A5);
align personal residency with corporate structure (see Article A6); and
and understand that the era of pure deferral without substance is over.
Next Steps
Need help with legitimate tax planning, international structural planning for your growing business or your personal portfolio? Book a scoping call.
We don’t time-bill and the initial call is free - click the ‘Book a Consultation’ button or email us at hello@ftr.finance today.
Important note: This article is general information for readers considering cross-border retirement or asset structuring. It is not personal tax, legal, or financial advice. Tax laws, visa rules, and treaty positions change regularly, and how they apply to you depends on your specific facts, citizenship, source of income, and prior tax history. Speak to a qualified adviser at FTR or elsewhere before acting on anything in this article.