The Centre for International Corporate Tax Accountability and Research’s analysis found tax structures involving Ireland and Bermuda ‘at the core of Microsoft’s global operations’
playbook that outlined the intense behavioural requirements placed on staff in charge of its Canadian operations to ensure profits from its e-commerce sales in Canada were booked in the United States. The e-commerce company did not deny using the strategy, but said it was outdated. Still, it demonstrated the intensity with which the world’s biggest businesses manage their taxes at the expense of the jurisdictions where they operate.
Ireland and Bermuda, two well-known tax havens that have been at the centre of the global taxation debate, figure prominently in CICTAR’s report. In Irish filings that the think tank found for the subsidiary Microsoft Global Finance for its fiscal year ending in June, 2020, CICTAR said it found the subsidiary is tax-resident in Bermuda, with its income exempt from taxes – and had $728-million in profit despite having no employees.
Much of the IRS case settles on “transfer pricing,” in which a company division or subsidiary sells a good, service or something intangible such as intellectual property to another division or subsidiary – often crossing borders.
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