Microsoft Canada’s Irish ownership offers a glimpse into multinationals’ tax strategies

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Microsoft Canada’s Irish ownership offers a glimpse into multinationals’ tax strategies
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It is legal and common for multinational companies to establish subsidiaries in tax-friendly Ireland, but it is rare to get a glimpse of exactly how their subsidiaries are shifted around

became owned by an Irish affiliate in its 2021 fiscal year, according to documents that offer a rare glimpse at how its multinational parent company has taken advantage of Ireland as a tax haven.

It is common for multinational companies to establish subsidiaries in tax-friendly Ireland, which has not yet implemented a multilateral promise to boost its corporate-profit tax rate to 15 per cent from 12.5 per cent. But it is rare to get a sense of exactly how these multinationals’ country-specificwithin a labyrinthine corporate structure.

It is not clear how much profit or loss Microsoft Canada books, nor is it clear how much it reduces any profits through payments to its Irish parent. Though some cross-border royalties are taxable, Geoffrey Loomer, an associate dean at the University of Victoria’s law faculty who studies tax law, said that, in practice, most are generally exempt from withholding tax.

The Irish filings for Microsoft Round Island One’s 2021 fiscal year show it became tax-resident there the day after the country stopped allowing widely publicized “Double Irish” tax strategies, which allowed Dublin-registered companies to be considered tax-resident in an offshore country with lower, or even zero, corporate tax.

“For tax reasons, Microsoft might just aggregate all the subsidiaries under the umbrella of the Irish for their own global tax-planning reasons,” she said. “There is no public disclosure on the shift of ownership of Microsoft Canada to Microsoft Round Island One and the subsequent transfer to Microsoft Ireland Research, both subsidiaries incorporated in Ireland,” Mr. Ward said. “If not for tax avoidance, what is the purpose of Microsoft owning Canadian and global operations through Irish structures that were previously tax resident in Bermuda?”

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