Over the past ten years, the Silicon Six have generated $11tn of revenue and $2.5tn of profits, which has been subject to just 18.8% corporate income tax across the globe at a time when the combined corporate income rate averaged 29.7% in the United States and 27.0% worldwide. If one-off repatriation tax payments connected to historical tax avoidance are excluded, the Silicon Six’s corporate income tax contribution falls to 16.1% over the past decade.

Over the period 2015 to 2024:

• the gap between the headline rates of tax and the corporate income cash taxes actually paid was $277.8bn
• the gap between the current tax provisions and the corporate income cash taxes actually paid was $82.1bn

Despite nearly half of their revenue (49%) being derived overseas, just 36% of profits are booked outside the United States and just 30% of current tax provisions are reported as being ‘foreign’ over the past ten years – with the corporate income cash taxes paid overseas being likely lower still. Overseas revenue would seem to be generally subject to much lower rates of income tax than US-booked domestic revenue – due to a combination of lower booked margins and profit-shifting to low-tax jurisdictions.

There is evidence that aggressive tax practices are still firmly embedded among the Silicon Six. Their reported uncertain tax positions have more than tripled over the decade, and now collectively total $82.5bn. In other words, the Silicon Six have claimed $82.5bn of tax benefits that they believe they will likely lose upon tax authority audit. Furthermore, the persistent growth in these tax contingencies is likely to be substantially inflating the reported tax charges of the Silicon Six and presenting a false impression as to the size of their tax contributions.

Much of the Silicon Six’s overseas revenue is subject to ‘tax haven’ level rates of corporate income tax in the United States via a tax break for foreign-derived intangible income. This is especially so at Meta (Facebook), Alphabet (Google) and Netflix, where the Foreign-Derived Intangible Income (FDII) deduction reduced their effective tax rate by a substantial five percentage points each in 2024. The FDII has been worth $30bn to the Silicon Six over the past three years alone.

Our ranking of 2025 once again matches that of 2019 and 2021: with our ranking of worst tax conduct as follows:

• 1st Amazon
• 2nd Meta (Facebook)
• 3rd Alphabet (Google)
• 4th Netflix
• 5th Apple
• 6th Microsoft

To redress the situation, and ensure a fairer tax contribution, it is suggested that:

• The United States end the FDII tax break and embrace the OECD 15% Global Minimum Tax.
• Other countries give more serious consideration to the degree to which the Silicon Six’s overseas revenue is subject to low levels of corporate income tax and develop more assertive responses to ensure that a fairer tax contribution is secured and so that more equitable business competition can operate within their jurisdictions.
• The UK should additionally catch up with international peers in Europe and Australia and mandate public Country-by-Country Reporting by multinationals, so that it is clear what revenue, profit and taxes are being paid in each jurisdiction.