Google closes a tax dispute with the Italian tax authorities by paying €326million. The Milan prosecutor’s office, which was investigating tax evasion on Google Ireland Limited, requests the archiving of the proceedings. This is stated in a note signed by the prosecutor Marcello Viola.
The Milan Public Prosecutor’s Office, Viola writes, “has submitted to the Preliminary Investigations Judge a request to close the proceedings” against “the Irish company Google Ireland Limited following the investigations delegated to the military of the Economic and Financial Police Unit of the Guardia di Finanza of Milan and at the end of the adhesion assessment procedure concluded by the company with the Revenue Agency for the years from 2015 to 2019”.
The investigations “showed that the foreign company, in relation to the activities conducted on the national territory, had failed to declare and pay taxes on income produced in Italy through a supposed hidden permanent establishment of a material type consisting of servers and the essential technological infrastructure for the functioning of the homonymous platform for the offer of digital services”.
In particular, “the failure to submit the annual declarations of income produced in Italy and the failure to submit the annual tax substitute declarations, in relation to the withholdings that Google Irl should have applied on the royalties paid to foreign companies belonging to the same Group, due to the use and exploitation, by the permanent establishment, of all the programs, algorithms, trademarks and intellectual property constituting, as a whole, the Google technology” emerged.
During the investigations, “the entire economic activity carried out by the company was reconstructed, with particular reference to the revenues obtained through the sale of advertising space, with the consequent contestation of the failure to declare the significant income deriving from such operations”.
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