Fiscal Paradises, The Case Of Google

Fiscal paradises, the case of Google

Summary

The main objective of the work is to publicize the mechanisms so complex that a multinational uses such as Google to manage to reduce tax taxation and on the other hand, explain what are the most recent measures that take organizations such as the European Union andEuropean countries to try not to continue using these mechanisms by multinationals.

Keywords

Fiscal Paradise, Taxes, Google, Double Irish, Dutch Sandwich

Introduction

The theme that will be presented later is to see in which form large multinationals such as Google take advantage of countries or places where taxation is low or in some cases even void. As we will see later, a package of measures promoted by the European Union has entered into force with the aim of combating fiscal elusion and we will also talk about a new rate that we want to impose throughout Europe but that has not yet been possible to generalize, butThe European Union tries to expedite processes so that this problem is over soon.

With this work it is intended to make known how multinational companies take advantage of these places of low taxation and also teach what are the mechanisms that are usually used for the elusion of taxes. On the other hand, possible solutions that can be made to end or at least reduce these situations will be mentioned.

To carry out the study of this issue, a theoretical framework will first be presented with which it is intended to explain the basic and key concepts to then be able to understand the mechanism and processes carried out by multinationals on the subject of tax.

Once the theoretical framework will be shown, the topic in question will be explained and supporting us in the theoretical framework, it will be explained as multinationals such as Google take advantage of these situations of low taxation and what mechanisms are those that use to carry it out. Finally, there will be measures that are being raised today in the affected governments and in the European Union and conclusions on the exposed topic will be given.

Theoretical framework

Tax havens

When talking about tax havens we have to indicate that there is no unique denomination to refer to them.

Thus, when referring to fiscal paradises, we will be mention.

We must not confuse fiscal elusion with tax evasion, since the second is considered a crime unlike the first term. That is, the evasion seeks to avoid the payment of the totality or most taxof the legal framework.

A fiscal paradise can be a country, a territory, a certain region or also an economic activity that seeks to privilege in front of the rest, in order to capture strong investments, constitute societies, host natural persons with large capitals, etc. In other words, tax havens are those sites that attract foreign investors for the favorable tax treatment they receive. As you can see, the term “fiscal paradise´´ admits multiple possibilities, so it is advisable to use the term“ countries or areas of low taxation ”.

Characteristic

The characteristics that this type of territories have in common are the following:

•  Low level of income imposition.
•  A strict bank secrecy: only client data to foreign authorities in case of very serious crimes are provided, and not always (terrorism crimes, etc.).
•  The personal data of natural or legal persons who have properties or investments in these territories do not appear in public records, or the use of formal representatives (or nominees) is allowed.
•  The absence of a change control regime.
•  A flexible fiscal and commercial legislation for companies from other countries that are domiciled in this territory.
•  A double system of change controls, one for residents and one for non -residents.
•  The scarce or no firm of double imposition treaties, so there is no exchange of fiscal information with other countries.
• Few limits to capital movements.
•  In addition to a highly developed banking sector with highly qualified personnel.

 Main agents in the use of paradises

The agents who use fiscal paradises the most are three: banks, multinational societies and large heritage.

First, banks use these paradises with the aim of paying a lower fiscal burden and at the same time dodge the supervision of their national central banks. It should be added that these also seek to escape the rules of their states that require them not to incur great financial risks.

As for the great heritage, what they seek is to hide their identity through these places of low taxation, take advantage of bank secrecy and the little exchange of information that exists in these places. In addition, they take advantage of the ease that exists to create both societies and other types of legal figures.

Finally, large multinationals, like financial companies and great fortunes their main objective when using these low tax imposition places is to pay the least possible amount of taxes.

 Forms of evasion

As the main objective of this work is to know how multinationals such as Google take advantage of tax havens, we will briefly describe what are the three most used forms to hide the benefits.

The first way is "transfer prices". It consists that matrix-philial between them is transferred whether tangible or intangible goods or service provision, then the company that crosses them changes the market price getting losses so that being in a country with a high foul load will not payso many taxes and now the other company, being in a fiscal paradise takes advantage of the sale to obtain benefits which will not have to pay for them.

The second way is to use interest payment. Legally it is allowed to deduce the payment of the interest that a company can have when requesting a loan, so they take advantage of this to transfer yields using loans between subsidiaries.

And finally the third way is through the placement of patents and brands in tax havens. The multinational asks the subsidiaries to pay high canons for the use of these intangibles, thus managing to move in a camouflaged way the benefits of the place where fiscal paradises operate.

Jurisdictions

Depending on the country or the agency we are talking about each one establishes their own criteria to determine what is called Fiscal Paradise. This means that there is no single list of countries considered fiscal paradise, so we are going to refer to the list that is more recognized worldwide and is carried out through the Organization for Economic Cooperation and Development (OECD) and we will describeWhat characteristics is based to include these countries on that list. In addition, to see the difference in criteria and countries we will do the same with the list that Spain and the European Union (EU) and on what criteria are based to make their lists.

List according to the OECD

First, you will talk about the list made by the OECD on low -tax territories through the World Forum on Transparency and Exchange of Information. Later in the international organizations section, this forum and its main characteristics and practices will be discussed.

The list made by this body is carried out through two phases and once these are finished, we are provided with a general qualification to the jurisdictions that have been reviewed. The last review began in 2016 and its results began to leave in August 2017. This review was carried out on 268 jurisdictions and four types of qualification are applied, these can be: obediently, provisionally compatible, partially compatible, provisionally partially compatible and does not comply with. In Annex I, the complete list of the OECD is presented with all jurisdictions and qualifications.

In this section we will only highlight the only jurisdiction that is considered by the OECD as a fiscal paradise as of March 2019, since this does not comply with the recommendations presented by said agency, that is, this jurisdiction was applied for the fast -track review, but the progress he demonstrated was not enough to justify an update of his qualification beyond breach. This is because the legal and regulatory framework reviewed in the first phase and the implementation of this regulatory framework are not adequate. This jurisdiction is Trinidad and Tobago.

1. If the jurisdiction does not impose taxes or these are only nominal (fictitious or not effective). The OECD recognizes that each jurisdiction has the right to determine whether imposing direct taxes. If there are no direct taxes, but indirect, the other three characteristics are used to determine if a jurisdiction is a fiscal paradise.

two. If there is no transparency.

3. If administrative laws or practices do not allow the exchange of information for fiscal purposes with other countries in relation to taxpayers who benefit from low taxes.

4. If non -residents are allowed to benefit from tax sales, even if they do not effectively develop an activity in the country.

 List according to the EU

The list made by the EU on non -cooperative jurisdictions was agreed by the Member States on December 5, 2017. And this list has been updated over time depending on whether these countries have been complying with the recommendations or indications that the EU has given. It should be noted that the EU performs two lists, one called blacklists in which the territories that do not comply with the recommendations are located and, on the other hand, the gray list composed of those countries that have commitments still pending to apply. Next, the countries that are in that blacklist updated on March 12, 2019 are presented and then this body will be detailed to introduce these jurisdictions into the list.

1. American Samoa
2. Barbados
3. Guam
4. Samoa
5. Trinidad and Tobago
6. EE Virgin Islands.UU
7. Aruba
8. Belize
9. Bermuda Islands
10. Dominica
11. Fiyi
12. Marshall Islands
13. Oman
14. United Arab Emirates
15. Vanuatu

The list is the result of an exhaustive selection and dialogue process with countries not belonging to the EU, to evaluate them based on the criteria agreed for good governance. 

These criteria are related to fiscal transparency, fair taxation, the implementation of measures against the erosion of the taxable base and transfer of benefits (called Beeps)of substances for countries without taxes.

The criteria were agreed by the Member States in the ECOFIN of November 2016 and were used as a basis for a ‘indicators’ detection indicators:

Fiscal transparency criteria. Criteria that a jurisdiction must fulfill to be considered to comply with fiscal transparency:

•  Initial criteria with respect to the Automatic OECD information exchange (AEOI) standard: jurisdiction, the legislative process must have been committed and begun to effectively implement the CRS, with the first exchanges no later than 2018 (with respect to 2017)
•  The jurisdiction must have at least one qualification of ‘largely compatible’ by the Global Forum with respect to the OECD’s information exchange standard (Eoir).
• For sovereign states, jurisdiction must have:

• Yo. ratified, agreed to ratify, be in the ratification process or committed to the entry into force, within a reasonable period of the OECD multilateral agreement on mutual administrative assistance (MCMAA) in tax matters or
• II. a network of exchange agreements in force before December 31, 2018 that is wide enough to cover all Member States, effectively allowing both Eoir and AEOI;

Fair tax criteria that a jurisdiction must comply with so that it is considered that it meets fair taxes:

• The jurisdiction should not have preferential fiscal measures that may be considered harmful, in accordance with the criteria established in the resolution of the Council and the representatives of the governments of the Member States, gathered within the Council of December 1, 1997, inA code of conduct for business taxation. Y
•  Jurisdiction should not facilitate offshore structures or arrangements aimed at attracting benefits that do not reflect real economic activity in jurisdiction.

Implementation of anti-benefits.

• Initial criteria that a jurisdiction must comply with the fact that it is considered to meet the requirements regarding the implementation of anti-benefits:

• The jurisdiction must be committed, at the end of 2017, the aged anti-benefits of the OECD, minimum standards and its consistent implementation.

List according to Spain

The list of countries or territories considered by Spain as fiscal paradises in the absence of regulations that determine them are those provided for in article 1 of Royal Decree 1080/1991, of July 5, excluding what was indicated by article 2 of the same of the samedecree. According to this last article, if these countries or territories sign with Spain an agreement for the exchange of information in tax matters or an agreement to avoid the double imposition with information exchange clause, they will cease to be considered tax havens at the time whenenter into force.

This list can also be updated under section 2 of the first additional provision of Law 36/2006 of November 29, measures for the prevention of fiscal fraud, so that certain countries will enter or leave this ‘black list’ attendingThe following criteria:

•  The existence with said country or territory of an agreement to avoid the double international imposition with information exchange clause, an agreement for the exchange of information on tax matters or the Mutual Administrative Assistance Agreement on fiscal matters of the OECD and the Council of Europeamended by the 2010 protocol, which is applied.
•  That there is no effective exchange of tax information under the terms provided by section 4 of this additional provision.
•  The results of the inter -pairs evaluations carried out by the Global Transparency Forum and Information Exchange for Fiscal Purposes.

1. Emirate of the state of Bahrain
2. Brunei sultanate
3. Gibraltar
4. Anguilla
5. Old and bearded
6. Bermuda
7. Caimanes Islands
8. Cook Islands
9. Republic of Dominican
10. Grenade
11. Fiji
12. Guaerney and Jersey Islands
13. Maldiva’s Islands
14. Man islands
15. Marine Islands
16. Mauricio
17. Monserrat
18. Republic of Naurú
19. Solomon Islands
20. St. Vincent and the Grenadines
21. St. Lucia
22. TURKS AND CAICOS ISLAS
23. Republic of Vanuatu
24. British virgin islands
25. Virgin Islands of the United States of America
26. Jordan Hachemitic Kingdom
27. Lebanese Republic
28. Republic of Liberia
29. Principality of Liechtenstein
30. Macao
31. Principality of Monaco
32. Sultanate of Oman
33. Republic of Seychelles

Being in its area of economic influence, the Principality of Andorra should be mentioned. With effects from 02/10/2011, date of entry into force of the Information Exchange Agreement in Tax Matters (BOE of 11/23/2010), the Principality of Andorra ceased to be considered fiscal paradise. On 12/07/2015, the agreement between the Kingdom of Spain and the Principality of Andorra was published in the BOE to avoid the double imposition on income taxes and prevent tax evasion and its protocol, made in Andorra la Vella theJanuary 8, 2015, which entered into force on February 26, 2016.

Ireland

The Republic of Ireland consists of a population of 4.8 million inhabitants, of which half resides in the capital, Dublin. The official language is English and has a parliamentary government system. With a GDP of 333.7 billion dollars.

When talking about Ireland we are talking about a country that has great tax advantages, one of the main advantages is that the Corporation Tax is the lowest in Europe, with the exception of Cyprus (see Graph 1). But, it also has a stability regarding the cost of work and has more than 70 fiscal agreements with countries around the world, this to fact that Ireland becomes a reference place for large multinational companies, which allocate large quantitiesof foreign direct investment (IDE) (see graph 2), in this graph you can see how during the 2007 crisis the IDE had a fall and once those years begin to grow although at a slow pace, until in 2012 it isIt produces a rapid increase in such investment continuing with the increase to the present, reaching 1.5 billion dollars of foreign investment. Foreign direct investment in this country focuses mainly on sectors such as financial, telecommunications, information technologies and the pharmaceutical sector. And this comes mainly from Luxembourg, the Netherlands, the United Kingdom, the United States and France.

The country does not have a specific regulation for the FDI, so the corporate, fiscal and competition regulations are applied exactly equal to that applied to the investment of Irish origin.

The country has two areas of low tax

1. International Center for Financial Services, located in the old docks of Dublin, for the installation of multinationals and financial institutions, which provide services to non -residents.
2.  Shanon Free Zone to attract investments from abroad aimed at creating industries.

Ireland has been very successful in the collection of companies. Large multinational companies have chosen the country to settle. An intelligent policy of support for business and low tax. In addition, it emphasizes that for digital companies or linked to knowledge, Irish fiscal law contains great exemptions for expenses in intellectual property and research and development. Import and export from here is noticeably better than in other European places. According to the economic freedom index, Ireland is the country with more freedom in Europe and the fifth in the world.

Holland

Holland is on the western coast of the Netherlands, with a population of 6.1 million inhabitants make up 36.7% of the population of the Netherlands. Its capital is Amsterdam in addition to being its most inhabited city. With a GDP of 826.2 billion dollars.

The attractiveness of this country from the business point of view are its great tax advantages, which make it very attractive to reduce the fiscal burden of societies in the heart of the European Union. As can be seen before according to the OECD. On the other hand, there are countries that consider that Holland makes unfair competition for their low taxation on business income.

Holland is not considered a fiscal paradise itself, because it does not provide opacity and bank secrecy that characterizes a fiscal paradise, but is a tax transit territory where taxes are optimized in a legal manner. Unlike fiscal jurisdictions classified by fiscal paradises, in the Netherlands, companies have to submit annual reports and their activities are transparent. That is, Dutch corporations can issue a carrier shares (Bearer Shares) and are obliged to deposit annually in the Dutch Mercantile Registry a copy of their audited financial statements. This transparency is what causes many people or organizations not to consider a paradise because with their transparency it is difficult to carry out illegal activities. You could say that Holland is a tax haven for holding companies and companies that work within the law.

Through the creation of a Dutch corporate company of actions (Holding Corporation), you can collect the benefits obtained in other countries and then transfer them again, this time to the country that truly interests us either to a fiscal paradise. Applying double -imposition treaties signed by Holland. If we add the Dutch tax costs of 5 percent, we find a combined fiscal burden of 19.25 per 100. The rest of money can be transferred to the country that is desired.

The double imposition treaties mentioned in the previous paragraph must also be highlighted as a great advantage, since Holland is one of the countries with the highest number of these agreements with other countries to avoid the double taxation. Thus getting that companies with operations in different countries are free to attend to the payment of taxes as in the vast majority of parent companies and subsidiaries. With this it is achieved that by recognizing the benefits in Holland and paying here, the money becomes clean money and is free to circulate.

The Bermuda Islands

The Bermuda Islands were discovered in 1503 by Juan Bermúdez, which gave the name to the islands. It is located a few kilometers from South Carolina and are composed of about 130 small islands in total that make up the archipelago, of which only about twenty of them are inhabited. It has an extension of 53 square meters and a population of about 65 thousand inhabitants, most of the population is located on the largest island (Gran Bermuda). According to the list of cia world factbook bermudas it has a 85 GDP per capita.000 dollars, standing above the United States.

According to the monetary authority of Bermudas (BMA) there are two types of societies: some are the companies that are owned by Bermudeños, which do not enjoy tax benefits such as the second type of society that we will see below. And on the other hand are societies that are constituted by foreigners. This last type of society is also called exempt society, which cannot carry out operations within the country unless they have a government permit.

Exempt companies do not pay taxes on profits, income or dividends, nor are it on capital gains, property tax or death. Nor is it mandatory to pay dividends.

Only one tax must be paid and this consists of a payment to the Bermuda government once a year, but if the company has an office with employees and is directed by two people, it is also exempt from the payment of said tax.

Finally, note that the most stand out on the island are the banking services, insurance, reinsurance and fund management. This makes 50% of GDP represented by the financial sector and tourism.

International organizations

Next, we are going to talk about the main organizations that at the international level are responsible for controlling the flow of capital that move through the international financial system with the aim of avoiding the possible illegal practices that can be carried out and what measures or actionscarry out to avoid it.

Financial Action Group Against money laundering (GAFI)

The financial action group (FATF) is an organization created in 1989 at a G-7 summit in Paris. Its objective is to establish standards and ensure that through these countries take legislative measures to end undue practices that affect the international financial system. The GAFI does not have a perpetual period of life, but that this is lengthening its life as long as its members approve it, currently its mandate is established from 2012 to 2020.

A year later of its creation in 1990 this body issued about 40 recommendations to governments. These were legal, financial, regulatory, police and intergovernmental actions, which were extended in 1996. Priority, broad measures affect the identification of people and societies that move money through tax havens, such as:

• Communication of the operations that are suspicious.
• Common concerted action of monitoring the countries of your blacklist.

• Monitor the economic transactions made by natural or legal persons from countries that do not cooperate in the fight against money laundering.

•  Banks must reserve online transactions for open accounts in a classic way, this is in person.
•  Financial entities will have staff that verify compliance with the legislation against money laundering.

• Identification and verification of the identity of the account holder and the final benefit.

It would not be until 2001 when he would announce 8 special recommendations against terrorism financing. And in 2004 I publish a last special recommendation to strengthen their objective of combating money laundering and terrorism financing. In addition, the different recommendations it makes with the objective that countries are adapted to the new practices of the world and the present, the last review of the recommendations occurred in 2012.

It is necessary to comment that these recommendations are not mandatory compliance by the States, but also leave their application for their application or not. But on the other hand, these recommendations are a basis for agencies such as the OECD, the United Nations Organization (UN) or the International Monetary Fund (IMF) to develop their own norms and principles in the fight against low taxplaces.

European Union

The EU has a fiscal anti-ovasion package that has as its objectives: that in the European Union there is a much less complex, more effective and fair joint taxation. This package has measures to avoid aggressive fiscal planning, greater fiscal transparency and greater equality for union companies. With this, the EU intends to help member countries take joint measures against tax evasion and thus get companies to pay their taxes.

The Fiscal Anti-Evasion Directive includes 5 measures that Member States must apply, as of January 1, 2019, against common forms of aggressive fiscal planning. These measures serve to create protection against tax fraud and also guarantee a more stable and fair environment for business societies. The measures of this directive are the following (more detailed explanation of the images continuation of these):

• Measure 1 – Rule of the Foreign Controlled Company (CFC)

• Before: companies could transfer their benefits to companies that were outside the EU in low -tax countries in order to declare a lower benefit in the country with the greatest amount of taxes.
• Now: with CFC measures, companies can continue to transfer their benefits to other companies that are outside the EU, but now these benefits will pay in EU.

In addition, the EU makes a list as we have seen before the non -cooperative countries in fiscal matters. With this list, the EU has the main objective that there are a good fiscal practice on the part of governments and ensure that all those international partners of member countries respect European regulations.

OECD

The OECD through the Global Forum on Transparency and Exchange of Information works in the fight against bad tax practices. This forum was created in 2000 and was restructured in 2009, since then it has become a key body when implementing international fiscal transparency standards. His work is aimed at both OECD countries and those outside this.

The forum is responsible for ensuring that these countries of fiscal transparency through supervision and peer review are applied in all countries of the world. There are two internationally agreed norms on the exchange of information for fiscal purposes:

•  Exchange of information on request (Eoir)
•  Automatic information exchange (AEOI)

The most used is the pairs of information exchange on request since 2009. This review is responsible for reviewing whether countries comply with the international transparency standard and information exchange at request. This review is carried out in two phases, in the first one is studied the legal and regulatory framework and in the second if this legal framework has been implemented in practice.

Once these two phases end, a report is carried out where the review results are shown and can include in those jurisdictions that do not meet the criteria analyzed recommendations to improve.

Fiscal Engineering

Fiscal engineering is a carefully planned strategy that aims to avoid, delay or reduce the payment of taxes of a person or company. Respecting at all times the current legality, this procedure takes advantage of legal gaps, inaccuracies in the laws and differences in the tax regulations of the different countries, in order to obtain a tax reduction.

Holding societies

A business holding structure is one in which a dominant society, also called matrix, has the totality (or at least, the majority) of participations from other dependent or subsidiary entities. It is a structure with benefits from different points of view (fiscal, commercial and organization), reasons why it is the most popular system used in business groups.

Its usual purpose is the shareholding of other companies to provide financing, emerge the trade fund (intangible assets such as the brand or the client portfolio) and collect dividends, interest interest, “royalties´´ or royalties, or exploitation rights. Through them the transfer of the property of a company in a country can be made through the sale of the “Holding´´ Society that has the actions in an offshore jurisdiction. This sale and the change of ownership can be made without paying in the jurisdiction where the company acts. This procedure is usual when acquiring other companies based on a third country and is one of the reasons for the popularity of tax havens to channel investments to third countries.

Methodology

For the realization of this work, the information of both previous investigation text books on tax havens, tax elusion mechanisms, jurisdictions, etc. As information from electronic newspapers and websites have also been extracted to obtain the most current information of the topic discussed. Once the information from these sources was obtained, it was valued what the most convenient information to enter at work was, thus getting the work collected the most important information. It should be noted that although the sources of textbooks can seem a bit outdated do not influence when analyzing the objective of the subject, because with these sources they have explained terms that today continue to mean the same thing the same thing. On the other hand, to analyze the main objective if the most recent information has been drawn through the Internet.

Google case

According to the OECDE Google pay average worldwide 1.5% taxes, while a normal citizen can pay 20 or 30 points more than the American multinational.

According to newspaper El Economista in an article (Romera, 2019) Google achieved in 2016 a benefit in 12 Bermuda of 12.600 million euros and tax for this. We can also find articles such as the Reuters website that says that in 2017 Google sent 19.000 million euros through a Dutch company Bermudas thus avoiding paying taxes (Meijer, 2019).

These benefits are achieved through aggressive fiscal planning. This planning consists in carrying out two practices, called "Dutch sandwich" and "the double Irish’´´. Next, we will explain what each of these practices consists of.

Irish double

A multinational has three societies, one in Ireland, another in Spain and the last in a fiscal paradise such as Bermuda. Now the multinational company does the following transfers the business to the company that is located in Bermudas and it sells the business again to Ireland and this is reversed to the company that is in Spain.

At that time a person is going to buy from the company that is in Spain and pays 20 euros for a mobile phone, of those 20 euros they go to the Ireland company 19 euros because Spanish society says that she paid those 19 euros to paidIreland’s and the latter in turn says that I buy that mobile from the fiscal paradise company paying 18 euros. In this way, all income obtained in Spain has ended up in a country that has no taxation.

As all this is achieved, it is because Ireland has agreements and agreements with low -tax territories and this allows any transmission of money between Ireland and a company located in a paradise does not have problems when performing said operation. This is caused that many not to say all US technological multinationals such as Google use Ireland so as not to pay any money worldwide.

Dutch sandwich

Let’s think of a multinational such as Google that obtains benefits all over the world with its companies, this implies that you must pay taxes in each of the countries that generates benefits, but instead of this the multinational goes to Holland and gets in touchWith the government of that country to obtain an agreement. This agreement consists in agreeing a price for Google. The thing does not end here, now that all the money is located in Holland is transferred to a territory of low taxation without hardly paying anything for this transfer.

This is achieved since Holland has a fiscal agreement with paradise and is that the benefits you send to paradise only pay 1%.

In short, Google combines “Dutch sandwich´´ with“ the double Irish’´ ‘getting four companies to pay any taxes.

Measures

One of the most current measures that have been proposed to prevent large technological multinationals do not pay taxes is the so -called Google rate.

As explained in an article on the Xataka website (Pérez, 2019) this tax is aimed for large technology companies such as Google, since conventional companies pay 23.5% on average in taxes, while technological ones lopay 9.5%. According to data from the European Commission itself.

However, this tax, although in Spain it is wanted to implement, there are countries like Germany that prefer to delay the implementation of said tax until there is an agreement between all the members of the OECD. And other countries that for their part do not want to implant as is the case of Ireland, Sweden, Finland and Denmark. For its part, the EU wants to wait until 2021 to discuss the subject.

Now we are going to explain what this Google rate in Spain consists of with which the government expects to raise 1.200 million annually. Well, as explained in the article mentioned before the Xataka page, the rate consists of a tax that will be aimed at companies with income in Spain of more than 3 million euros and the total revenues per year of 750 millioneuros. Companies must pay 3% on the billing of online advertising services, online intermediation and the sale of user information data. Being excluded those e -commerce retail activities. This tax will be set for quarters and the accrual will depend on each provision of services subject to this.

It is also necessary to mention in this section the anti-evasion measures that must begin to be taken by the Member States as of January 1 of this year. We are talking about the measures mentioned in the EU section and especially the first measure of the controlled foreign company that would greatly affect Google in its practices that leads to traces of the Irish double, moving its benefit of acountry with high taxes to another with a lower fiscal burden. This measure would force him to pay taxes in the country in which he has generated the benefits.

Conclusions

As stated at the beginning of work there is no single list of tax havens, since each body takes into account their own criteria to consider them as such. Although, regardless of this, a fiscal paradise is a place where both great fortunes, multinationals or financial companies take advantage of the low taxation that exists and the legal gaps. It should be noted that the search for information on this issue studied is not a simple task since this is worth these territories of low taxation, of the little information that is made known in order to carry out their practices.

Therefore, arrived at this point of the work we can say that there are many companies that are enough of quite complex mechanisms in order to avoid paying most of the taxes. There is no single way to carry out these practices as we have seen, but in this work we have focused on explaining especially the mechanisms that Google uses to avoid taxes, they are also the same mechanisms that use large multinationals also well known as they are Facebook, Apple, Amazon, etc. Hopefully the most recent measures we have exposed to avoid this taxation of tax.

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