An adviser to an administrative court in France has said that Google is not
liable for EUR1.1bn (USD1.2bn) in back taxes because the company lacks sufficient
presence in the country.
According to numerous reports, the adviser to the administrative court in Paris
argued at a hearing on June 14 that Google does not owe the back taxes being
demanded by the French tax authority because it does not have a permanent establishment
A court ruling is expected in the case in mid-July, although the adviser's
opinion is non-binding.
In May 2016, Google's offices in Paris were raided by more than 100 investigators
on behalf of France's tax authority. France's prosecutor's office said at the
time that the "searches are the result of a preliminary investigation opened
on June 16, 2015, relative to aggravated tax fraud and organized money laundering."
"The investigation is aimed at finding out whether Google Ireland Ltd.
is permanently established in France and if, by not declaring some of its activity
on French soil, it has failed to meet its fiscal obligations," prosecutors
The raid followed confirmation from Google in 2014 that French authorities
were seeking payment of additional tax. A regulatory filing from the company
said that a notice from French tax authorities concerned the structuring of
Google's tax affairs, which it said allow Google to mitigate tax liability where
the company says it has limited operations, including in France.