Google is moving even more money through a shell corporation in Bermuda—reaching a total of €8.8 billion ($11.91 billion) in 2012, 25 percent more than it did in 2011. By employing a legal yet ethically questionable practice, Google is saving itself billions in taxes worldwide.

The new figures were first reported by the Financial Times on Friday, citing “[recent] filings by one of Google’s Dutch subsidiaries.” This widespread strategy of moving money around involves two specific tactics known as the “Dutch Sandwich” and the “Double Irish.” (Ars obtained a copy of this filing, dated September 27, 2013, from an anonymous source.)

As the Times concluded, these disclosures mean “that royalty payments made to Bermuda—where the company holds its non-US intellectual property—have doubled over the past three years. This increase reflects the rapid growth of Google’s global business.”

The British newspaper cited filings from Google Netherlands Holdings, which represents the “Dutch Sandwich” part of the equation.

Bermuda triangle of taxation

As Ars has reported before, here’s how the Double Irish works. Bloomberg first described the process in 2010: a company sells or licenses its foreign rights to intellectual property developed in the United States to a subsidiary in a country with lower tax rates. The result? Foreign profits that come from that tech—like the rights to Google’s search and advertising technology, effectively the keys to the kingdom—are now attributed to that offshore subsidiary rather than the Mountain View, California headquarters. The subsidiaries have to pay “arm’s length” prices for those rights, just like an outside company would.

Bloomberg concluded, “Because the payments contribute to taxable income, the parent company has an incentive to set them as low as possible. Cutting the foreign subsidiary’s expenses effectively shifts profits overseas.”

So who does Google license its tech to? A fun little company called Google Ireland Holdings, headquartered in Bermuda. Bermuda, of course, has zero corporate income tax. So as a Bermuda company, Google Ireland Holdings pays none.

Google Ireland Holdings, in turn, owns Google Ireland Limited, which employs 2,000 people in downtown Dublin. Google Ireland Limited reported a pretax income of less than one percent of sales in 2008 and paid $5.4 billion in royalties to Google Ireland Holdings. (French investigative news site OWNI.fr published Google Ireland Limited’s 2011 annual report and its Irish Registration Office documents in 2012.)

This holding company based in Bermuda is owned by yet another Bermuda-based subsidiary, Google Bermuda Unlimited. It is managed by Conyers, Dill, and Pearman, a law firm specializing in such offshore transactions. That “unlimited” corporation means it is not required to disclose income statements, balance sheets, and other financial information.

But getting money, tax-free, from Ireland to Bermuda requires a stopover in the Netherlands (the "Dutch Sandwich" part) at Google Netherlands Holdings B.V. This entity, according to Bloomberg, “pays out about 99.8 percent of what it collects to the Bermuda entity, company filings show. The Amsterdam-based subsidiary lists no employees.”

Over the last year, various European countries, including the United Kingdom, the Netherlands, and France have been reviewing their laws that enable this type of corporate behavior.