The Silicon Six and their $100bn global tax gap

In December 2019, the Fair Tax Foundation undertook a forensic analysis of the tax conduct of the Silicon Six (Facebook, Apple, Amazon, Netflix, Google and Microsoft) and uncovered a $100bn global tax gap over the decade to date (which was then, 2010-18/19).

In May 2021, this analysis was repeated for the 10 years 2011 to 2020 inclusive, and it was discovered that the $100bn tax gap is as enormous as ever.

There is still a significant difference between the cash taxes paid and both the expected headline rate of tax and, more significantly, the reported current tax provisions. Over the period 2011 to 2020:

the gap between the expected headline rates of tax and the cash taxes actually paid by the Silicon Six was $149.4bn
the gap between the current tax provisions and the cash taxes actually paid by the Silicon Six was $96.3bn

The bulk of the shortfall almost certainly arose outside the United States, given that the foreign current tax charge was just 9.3% of identified international profits over 2011-20. This would be expected to have a significant impact on the cash taxes paid contribution given 58.9% of total profits and 50.6% of total revenues are identified as being foreign over the decade.

In terms of ranking, none of the Six is an exemplar of responsible tax conduct. However, the degree of irresponsibility and the relative tax contribution made does vary. Amazon has paid just $5.9bn in income taxes this decade, while Apple has paid $100.6bn and Microsoft has paid $55.3bn.

Our ranking of 2019 holds: with our ranking of worst tax conduct as follows:

1st Amazon
2nd Facebook
3rd Google / Alphabet
4th Netflix
5th Apple
6th Microsoft

Silicon Six: taxes expected, booked and paid

Chief Executive of the Fair Tax Foundation, Paul Monaghan said: “Our analysis of the long-run effective tax rate of the Silicon Six over the decade has found that there continues to be a significant difference between the cash taxes paid and both the headline rate of tax and, more significantly, the reported current tax provisions.”

“These figures provide solid evidence that substantive tax avoidance is still embedded within many large multinationals and nothing less than a root and branch reform of interantional tax rules will remedy the situation. Fortunately, the new US administration has recently light a fire beneath the multilateral discussions that have been slowly progressing under the auspices of the OECD. The Biden-Harris proposals would see many of the incentives underpinning profit-shifting to tax havens removed, and would see the very largest multinationals taxed not just on where subsidiary profits are booked, but where real economic value is derived. This would have a seismic impact on the likes of Amazon, Apple, Facebook, Google and Microsoft (who have tax dodging hard-wired into their organisational structure), with billions of additional taxes paid across the world.”

“We could be on the cusp of a once in a generation moment, but world leaders at the forthcoming G7 and G20 world leader summits need to grasp the nettle, step up and engage with the agenda much more positively – the benefit to public services across the world could be immense.”

The Silicon Six analysis concentrates on the information contained in the Form 10-K annual filings in the United States, where the companies are incorporated. We have also selectively reviewed the company accounts of various European and UK subsidiaries, focussing attention on the cash taxes paid (as opposed to the total tax and / or current tax provisions, which are predominantly the focus of media analysis and policy consideration to date).

For the bulk of the decade (2011-17), the US operated a 35% headline rate of tax. Thereafter there was a permanent lowering of the top federal corporate income tax rate from 35% to 21% and the introduction of a repatriation tax on previously deferred foreign income at much reduced rates of between 8-15.5%. As of 2018, we have assumed that the foreign portion of profits is taxed at the GILTI maximum of 13.1%

Silicon Six: from revenue to cash tax paid

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