Google May Be $1 Billion Behind In Tax Payments To France

An anonymous reader writes "Ars Technica reports, 'Technology giant Google has been delinquent on its tax payments in France for the past few years, to the tune of more than $1 billion in missed payments, and it now may be hit with a sizable tax penalty by the French government.' Google asserts that it has operated within the law in France, but the French government has reason to believe that in order to avoid French taxes, Google has been passing off some of its business contracts as Irish rather than French."

Comments

$1B? That's nothing!

[Anonymous Coward]

Ever heard of the Double Irish and a Dutch sandwich?
The City of London has established a world-spanning network of tax heaven states, mostly consisting of former parts of the english empire. Big corporations use this system to not pay taxes, and the sums involved exceed 1$B by far.

Re:$1B? That's nothing!

[mrchaotica]

Property only exists by virtue of the law which exists thanks to taxation

Property exists by virtue of a person claiming and controlling it by fighting off those who would take it away. All the law does is make it so the owner doesn't have to physically defend it all the time.

Re:So few

[cheesybagel]

Google, Amazon, Apple escaping taxes and it starts to add up to real money.

Re:Same as UK

[Anonymous Coward]

Nope. No one goes to jail when the pile of money on the table is this large.
You have to be pretty small-time to get prison unless you've stolen from our real rulers, i.e. Bernie Madoff's mistake.

Re:So few

[bloodhawk]

I would not be surprised if between most of the major corporations that they owe the French more than 50 billion. Hate to cheer for a tax office let alone a French one but what Google et al do tax wise is fucking appalling and needs to be cracked down on by EVERY government.

Re:So few

[manu0601]

We have a good figure to start with: the share of GDP that goes to capital or labor. It moved a lot from the later to the former. Should we go back to 1980 values in France, workers (who cannot escape taxes as megacorporations can) would globally get a 195 billion euros bonus each year.

Same tricks played in UK

[whoever57]

Google has played the same tricks in the UK. Google claims that the sales are made in Ireland, while employing many people in the UK whose job titles includes sales. I expect there are Google employees in France and UK (and most other European countries) who get sales commissions for sales "made" in the Ireland.

Re:Same tricks played in UK

[mlts]

In cases like this, I wonder about just moving to a VAT entirely and dispensing with income taxes.

In a perfect world where companies paid what they earned, an income tax would be better in theory, as consumption taxes tend to slow down purchasing and movement of money.

However, in the real world, we read all the time about the stashing of income. A VAT is better because it is a lot harder to get around (as of now... I'm sure there might be loopholes.)

tl;dr... Income can be hidden. Hiding that factory, Lear Jet, or Maybach, not so much.

Re:Same tricks played in UK

[jemmyw]

The problem with sales tax (VAT) is that it taxes the poor more than the rich because the poor tend to spend a greater proportion of their income. It is also quite a burden to administer for companies and government. It is also an inefficient tax for states with welfare - government gives you money and then you give a large portion of it back again.

I don't have a solution though, even though it is something I think about often. But it seems to me that what we really need is for some way to experiment with widely different tax regimes. But what country is going to be willing to suffer negative consequences of doing so?

Re:Same tricks played in UK

[Anonymous Coward]

In cases like this, I wonder about just moving to a VAT entirely and dispensing with income taxes.

In a perfect world where companies paid what they earned, an income tax would be better in theory, as consumption taxes tend to slow down purchasing and movement of money.

However, in the real world, we read all the time about the stashing of income. A VAT is better because it is a lot harder to get around (as of now... I'm sure there might be loopholes.)

tl;dr... Income can be hidden. Hiding that factory, Lear Jet, or Maybach, not so much.

VAT, or sales taxes don't work on a level playing field. If you make a low wage the vast majority of your money is spent on housing, then on the repeat purchasesables. Food, household items like garbage bags, dishsoap, clothes, and possibly fuel.

Most of your spending is taxed, a decently high rate. When you make 10-15k a year 15 precent or so sales tax hurts. A lot.

On the other hand, if you make 10 or 20 times that much you don't spend 10 or 20 times as much on the same things. You'd spend a little more. Higher quality goods do cost more, but unless you are doing hilarious things with your wealth like buying solid gold Lambo's chances are you aren't spending anything close to a similar ratio. Even a good house (mansions are a whole nother thing) doesn't cost that much more than renting an apartment.

The richer you are the less a sales tax hurts, when that's the opposite of the way you want to distribute a tax burden.

The examples of factories, lear jets, that kind of thing. Rich people don't own their own toy's if they are smart. That Lear Jet? Its a Company Jet, which means it'd actually a tax deduction as a business expense. That's right the private jet let him pay less, not more taxes.

If we're going to get really sneaky, we can double down on Company's. Lets incorporate a Transportation Company that exists solely to own this Lear Jet, its only income is renting the Jet to our theoretical rich man. To offset this income it has the operating costs of the jet, gas, maintenance, fuel, the pilots salary and a lawayer/accountant to run the whole mess.

Except this Company doesn't own the jet either. Much like a bank loans you money so you can buy a house, a third company exists solely to loan the money to the second company to buy a jet with. And since we control both companies, we'll make some silly terms, like a 100 year repayment plan, with interest payments tailored to the setup so that the Transportation company will stay in the tax bracket we desire. In fact, lets make sure the Transportation company slowly loses money over time, so they qualify for all those tax incentives the government sets up to help small businesses, and since the transportation company doesn't own anything, if there is ever an accident or something there are no assets to sue for. All it owns is a big fat debt on the Jet which Company number three can repossess if necessary.

Now we put each of these companies in whatever country has the most favorable laws for each circumstance.

This is the problem with tax laws. Not that Google (or any, hell, lets be honest, EVERY, multi-national corporation) owes money, its that the tax laws are so messed up that the above scenario is possible, legal, and if I had to guess, probably simplistic.

I love beating on mega-corps as much as anybody, but I'd put money that Google has been following the letter of the law in France. They have teams of very highly paid lawyers to make sure of it after all. France is just pissed somebody figured out how to game their system.

Re:Same tricks played in UK

[jemmyw]

No, it will hit the poor harder. It doesn't matter the amount of money, it matters the proportion. If a less well off person spends 100% of their earnings on rent, food, water, etc. then they'll be taxed the full amount, and for the basics they have no choice. A very well off person won't be spending 100% of their income even if they buy that luxury yacht, and they don't even need that yacht so they could choose not to make the purchase and invest instead.

Re:So few

[Noah Haders]

there's a difference between structuring your business to avoid taxes, and not paying taxes that you owe. Goog is the latter. but I feel bad beating up on them lately, especially after the moto thing and their last quarterly report. desktop revenue down 9% even though clicks are up 26%...

Re:So few

[Anonymous Coward]

If they don't like the laws the company is free to not operate in the country. If they choose to operate there they must follow the law. I have no sympathy for them, they knew what the deal was when they stablished there.

How they get away with it (for now)

[Anonymous Brave Guy]

Giving the benefit of the doubt, and assuming this a genuine question and not a troll...

The problem is that it is surprisingly difficult to objectively distinguish between legitimate activities in an international business that operates in under multiple tax regimes and the activities which are "obviously" just tax avoidance.

It's hardly a secret that some businesses set up a legal entity that is little more than an administrative formality in a country with a very low corporation tax rate, and then their legal entities in other countries with higher corporation taxes pay some sort of fees/royalties to their low tax counterpart, thus shifting the tax burden and saving them money (as well as changing which country is the beneficiary of the corporation tax they do pay).

The trouble is that the same rules about international payments and taxes have to cover businesses that really do operate, for example, a crucial R&D lab in one country (perhaps with a good reason, such as having close ties to a good university nearby) but still sell the end product to customers internationally. More than that, you also have to allow for the fact that it might be two completely separate legal entities doing that, which may or may not be owned by some of the same interests. After all, if a business in one country spends a lot of time and money hiring smart people to design products, but then sells the IP rights to completely independent manufacturing businesses in other countries that make and sell the physical products, I don't think many people would argue that it's silly to have the money for the rights shifting across international borders back to the people who did the research, and for each individual company involved to pay the appropriate tax in their own country on the money they make in that country.

So where do you draw the line, and on what basis? After all, the businesses in question almost certainly do still pay substantial amounts of money to the countries where they really are selling things, such as sales, property and employment taxes. The "obvious" thing to do is to adjust the tax rates so corporation tax is universally low and more government revenue comes from these other forms of taxation that can't be so readily shifted, but that has a lot of knock-on effects for your entire national tax system, and it's also susceptible to various other kinds of manipulation unless there is a lot of international co-ordination to mitigate those dangers. And remember, the people who are making all this money typically have a lot more to spend on professional tax advice -- and get excellent returns on that investment -- than the governments in question have to spend on challenging them in extended tax-related lawsuits that will drag on for years at great cost to all concerned.

I think there is sufficient public opinion turning against the more egregious examples of corporate tax avoidance now that we really will see such international co-ordination starting to get results within the next few years. France is definitely not the only place concerned about this, at either government or guy-in-the-street level. But for now, the above is (a grossly simplified explanation of) how they get away with it, and why it's neither breaking any laws nor easy to make laws it would break without unintended and potentially very nasty side effects.

Re:How they get away with it (for now)

[IamTheRealMike]

Really?? What is so hard? An American company setting up in Ireland/Singapore etc to sell goods to third country X. It isn't hard to distinguish at all

What makes you think Google is an American company?

Yes, it was founded there. But more than half its employees and more than half its revenues are outside the USA. Looking purely at the numbers as they are today, Google is not an American company.

So what country does "own" Google then? Ireland? No. Most of Google's operations are not in Ireland. France? Certainly not.

Now we see the crux of the problem. Google is in fact a truly trans-national company. It is not obviously located in any one place. It has offices, employees and customers everywhere, and its products are all online where there are no borders.

How do you decide which countries get the biggest slice of the cake? There is no rational way to do it which is why people who design tax systems like the EU designed it to create a deliberate race to the bottom.

Re:How they get away with it (for now)

[WoOS]

But a revenue tax would stop all manners of shady profit shifting and hiding.

There is already a tax on revenue. It is called VAT and has its own tax evasion problems.

Doing a revenue tax in any other way than as a value added tax will immediatly give you massive vertical integration in the industry as companies not producing their own intermediate goods indirectly have to pay "revenue" tax on them with no way of deducing it from their own revenue tax. Thus you end up with more "too big to fail" companies.

Re:How they get away with it (for now)

[gbjbaanb]

No, Google is an Irish company. If you look at which of the many companies that comprises Google worldwide, it is Google Ireland that does the majority of business with all the other countries in fact, this individual country's operation actually does all the selling of product in all the other countries too - that's why the tax bill is so low.
See, if in France, a French salesman sells an advertising campaign to a French company, it is the Irish company that does it - otherwise the sale would (obviously) count as a French sale by French people to Frenchmen, and thus then be liable for all those taxes. But if the Irish company did the selling (nudge, nudge, honest) then the tax bill is massively reduced, especially as the licensing for this sale is managed by a different Irish company (only this one is registered in Bermuda.... hence the term "double Irish" - it requires 2 Irish companies, one registered elsewhere. These are Google Ireland Ltd and Google Ireland Holdings. One does all the sales, the other does all the licencing of IP to the other. Between them, I could happily say they do all of Google's business). A simple explanation

That's the problem - not some 'grey area' where you have to draw lines over which company does business in which country, or some amorphous global company doing business everywhere. Google is an Irish company that just happens to have a "subsidiary" in California where the CEO lives.

So Google Ireland acts as a conduit - in 2009 it turned over nearly â8bn, yet profits were only â45m.

Maybe the US system of allowing related companies be treated individually for tax purposes should be scrapped. Then Google Ireland, Google Bermuda, and Google would be considered together for taxation by the US taxman...and the US would start to receive tax that is currently held outside US borders.

Re:Hard to follow what going on

[RJFerret]

According to the DGF investigation, the company only sends Google Ireland contracts, but they are written in French with French clauses, and therefore considered French contracts.

They should stop reading them via translate.google.com.

Re:So few

[Anonymous Brave Guy]

The problem is that they are following the laws in these countries. The governments have the legislative powers and have created tax systems that don't work under these conditions, but instead of fixing the problem, it's politically better PR to just blame the big organisations for having decent accountants.

In cases where that creates a hostile public feeling toward a company, that can be a surprisingly effective strategy -- certain businesses that operate in the UK have recently changed their accounting practices so they declare more taxable income in the UK -- but usually the amounts involved are relatively small, just enough to counter the bad press with a good soundbite about how many million they paid in tax last year -- and it doesn't really work on businesses that utterly dominate their industries and/or don't deal much with the average guy in the street anyway.

Sooner or later, these governments are going to have to get their act together and fix the broken system properly, but I suspect a lot of them are hoping the next election will come and go first so either they have some breathing room or it's someone else's problem.

Re:So few

[kesuki]

you didn't provide links verifying your points. without links it is too hard for the people who regularly get mod points to mod positive, because if you want a soap box on slashdot you should use their journal system. having read the definition of austerity measures it is clear that the usa is also using austerity measures... the world is a complex place, though.

"After the french government committed to economic suicide with austerity policies" http://en.wikipedia.org/wiki/Austerity In economics, austerity describes policies used by governments to reduce budget deficits during adverse economic conditions. These policies may include spending cuts, tax increases, or a mixture of the two.[1][2][3] Austerity policies may be attempts to demonstrate governments' fiscal discipline to their creditors and credit rating agencies by bringing revenues closer to expenditures; they may also be politically or ideologically driven.

In macroeconomics, reducing government deficits generally increases unemployment in the short run.[4] This increases safety net spending and reduces tax revenues, partially offsetting the austerity measures. Government spending contributes to gross domestic product (GDP), so reducing spending may result in a higher debt-to-GDP ratio, a key measure of the debt burden carried by a country and its citizens. Higher short-term deficit spending (stimulus) contributes to GDP growth particularly when consumers and businesses are unwilling or unable to spend. This is because crowding out (i.e., rising interest rates as government bids against business for a finite amount of savings, slowing the economy) is less of a factor in a downturn, as there may be a surplus of savings.[5][6]

Re:Same as UK

[tlambert]

Google seems to be consistently dodging taxes. Shouldn't people go to jail for this?

If you set up rules by which something is legal, and someone jumps through the necessary hoops to follow those rules in order to pay the minimum possible taxes, the only thing you really have a right to complain about is the rules you've set up, not that people follow them in an optimal fashion.

France is (effectively) paying Google $266.5M to execute their contracts in Ireland rather than France, due to the 33.3% corporate tax in France, vs. the 12.5% corporate tax in Ireland.

If France wants to tariff EU transactions, they need to drop out of the EU; if they want the $162.5M from Google that's going to Ireland instead of France, then they need to drop their corporate tax rate by 20.8% to match Irelands ...or drop out of the EU.

If it weren't for the loading (multiple incorporations, intellectual property assets capable of being licensed for large feed, lawyer costs, professional board member costs in the NL, etc.), pretty much no one would actually do business in France directly, as a legal venue.

Re:So few

[smittyoneeach]

Should Google just buy France?

Re:So few

[PopeRatzo]

In some countries, maybe there's some blame to be had for escaping taxes...but France is a whole other argument. I mean shit, 75% tax on the wealthiest has resulted in a lot of them just flat out leaving that country. It got so bad that their dear leader is now lobbying against his own tax plan; the same plan that put it there to begin with.

What do personal tax rates have to do with a corporation paying corporate taxes? There are no "75%" corporate taxes in France?

A corporation has a choice in whether or not to do business in a country. Google has no problem doing business in countries with regimes with a lot worse policies than a 75% top personal tax rate.

Re:Same as UK

[rtb61]

Keeping money is tax havens makes paying bribes in tax havens with secret bank accounts real easy. Politicians collect the bribes by going on luxury holidays and spending up big on 'souvenirs' which they bring back with them to pay for corrupt legislation, in corrupted democracies all over the globe. Many corrupted democracies conspire together to keep tax havens alive, rather than actually doing anything about it. The top dog in corruption is of course the US, which then uses it's economic and military power to push that high level corruption upon the bulk of the globe.

Re:So few

[Blaskowicz]

Dear leader? The French president is more like Ronald Reagan than Dear leader lately.
The 75% for income above one million euros (after deductions), was a symbolic measure as it concerns very few people and is still not applied. Just stuff waived around to get elected. Same president had pleaded to renogotiate the treaty on European Stability Mechanism, but didn't. Not a single point or comma was changed. Now this government will get us in the Great Transatlantic Market, or whatever it's called in which US corporations will dictate their laws to the countries and European Union, putting an end to national democracy.

Dear leader my ass! We're trapped, with a presidency and governnement that have "socialist" in name but are right-leaning collaborationists, more in the way of Tony Blair and Gehrard Schroeder.

Re:So few

[Krishnoid]

Goog is the latter. but I feel bad beating up on them lately, especially after the moto thing and their last quarterly report. desktop revenue down 9% even though clicks are up 26%...

For Google's case in particular, I also have to look at the services they've provided:

• High-quality email with the holy grail of spam filtering
• Basic office software in a browser
• A standards-compatible browser under constant development
• A phone operating system
• Mapping, search, and everything else

Since these are provided free to everybody, isn't this a tangible public service? Sure, Google's users are the product, but if one considers these as analogous to services provided under a government's mandate to use their taxes to provide for the general welfare, why shouldn't Google get a special tax break? It sure beats the return on the multiple $1E9's spent beating the crap out of some foreign country.

Re:So few

[skegg]

Very true.

France, join the club: Apple, Google facing tax crackdown

Re:So few

[flyingfsck]

Sure, but Google (and others) are obviously trying to pass off work done in France (or other EU countries) as work done in Ireland, while the Ireland office obviously has very few staff and cannot possibly do all the work they are purported to be doing. This is a very obvious tax fraud and it is quite amazing that these mega corps think that they will get away with it forever. They should get audited and double taxed. Simple as that.

Re:So few

[Vapula]

The problem is the Ireland tax loophole. It's abused by Google, Apple, Microsoft and many other.

Politician need to fix it... because the same happen in Belgium, Germany, ...

Re:So few

[the grace of R'hllor]

For much of the 20th century, the United States has had >70% tax on the wealthiest as well, with at some point >90%. Apparently, that did not seems to hurt the US.

Not that various American ultra-rich folks are calling for higher taxes on the wealthy too. Instead, they get tax breaks.

A few rich people being a bit upset that their income from labor gets taxed heavily, which they don't feel because the vast bulk of their income comes from investment, won't hurt them. It's the desire to spend spend spend that really gets Hollande. Actual socialists do more harm than good.

Re:So few

[davester666]

Actually, it really appears that Google was blatantly NOT following the law.

Apple sells an iPhone and says X% of the value of it is for patents to be paid to an Irish company [or something like that], which is completely legal, even if it is also completely arbitrary [as Apple owns said patents] so they basically shift most profits out of the country. Everybody and their dog does this, Apple just headlines this because they are a relatively new company [vs say, petroleum companies] and they make highest amount of profit [or thereabouts] worldwide.

Google has a large office of employee's in France, that were involved with negotiating and signing advertising contracts with french companies, then claiming those contracts were actually signed IN IRELAND. This is the part that the tax collectors are taking issue with. To be legal and not have to pay taxes in France for those contracts, Google would basically have to close their french offices and get everyone to directly deal with their Irish division.

And I believe I saw a similar story about the UK also investigating Google doing this in the UK as well. And I'm sure all the other tax collection agencies in the EU have perked up their ears and started taking a look at this...

Already something to cover that

[dbIII]

Google can try to register as a charity like all the others providing services and see how far it gets.

Re:So few

[Fuzzums]

"The government redrafted a proposed bill to levy a temporary 75% tax on earnings over 1 million Euros."
-- on earnings over 1 million Euros --

Personally I don't see the problem to contribute more to society if you earn that much money.

Re:So few

[Carewolf]

The US had a top marginal tax of 90% during it richest times of the last century. Why does it bother you so?

Re:So few

[Tom]

the wealthiest has resulted in a lot of them just flat out leaving that country.

Which is why tax laws need a lot more international corporations.

Right now, the rich and the mega-corporations are turning countries into enemies that fight each other over "competitive" tax rates, when they should be allies fighting the tax evaders with criminal prosecutions.

It's just another trick to make you and me pay indirect subsidies to the rich. Even if you're anti-government, you can't deny a simple truth: Every $ that some rich dude or corporations evades in tax payment has to be paid by the rest of us instead.

75% tax on rich does not exist

[aepervius]

I have no idea where you are getting that idea. http://en.wikipedia.org/wiki/T... there is a 60% tax on inheritance but only if you are a remote relative. There are high income tax on very high income (41% top), and there is a very low tax on wealth (around a 1% if you are millionaire , and atround 2% if youa re over 10* millionaire). As for the article it does not speak at all about a 75% tax. As for the article, it was really written by an american "France is famous for its generous social benefits, somewhat relaxed work ethic" there are country (like germany, Sweden) which have as generous and as relaxed "work ethic". In fact I suspect the usage of the word "ethic" here as being american prejudice only.

Re:75% tax on rich does not exist

[AlterEager]

"France is famous for its generous social benefits, somewhat relaxed work ethic"

That relaxed work ethic that gives France one of the highest GDP/hour worked in the world.

Re:So few

[AlterEager]

In some countries, maybe there's some blame to be had for escaping taxes...but France is a whole other argument. I mean shit, 75% tax on the wealthiest has resulted in a lot of them just flat out leaving that country.

The top French income tax rate (on income over EUR 151,200) us 45%.

Re:So few

[Coeurderoy]

You confuse taxes on individuals and taxes on companies, BTW the US top tax rate was very close to this until you elected a movie cowboy, I guess all the rich people where fleeing the US in the 60s 70s and early 80s ....

The main reason BTW the government is trying to increase personal taxes is just because international (including very french ones) companies actually manage not to pay any taxes...

Re:So few

[Anonymous Brave Guy]

TFA says that the French government thinks they are not following the laws.

But which part of the French government? The implication is very different depending on whether we're talking about the legislative authorities, the tax collection authorities, or someone's PR department.

Of course some countries, most notably the UK, are against this because they like being tax havens.

I think you're confusing the UK with Ireland. Large international businesses are playing much the same games to avoid paying corporation tax in the UK as they are in France.

Re:Alternative Minimum Tax

[killhour]

That will never happen. Since congress has the sole authority to set taxes, they realized way back that they can get a ton of leverage by negotiating for new tax rules. You want to push a new law through? Tax rule to grease the palms. McDonalds overcharged you for a Big Mac? Tax rule. Your best friend works in the Petroleum industry? Tax rule. It's 2PM on a Tuesday? Tax rule. Hell, the taxes are so complicated, entire industries have grown around figuring them out - and they're actively lobbying to prevent the simplification of tax rules, since that would be bad for business.

Re:So few

[AlphaWolf_HK]

Sorry, but that 90% figure is sensationalist and just another way to say "look, we're getting screwed by the 1% more than we used to! Torches and pitchforks now!" and ultimately isn't useful. Why? Because practically nobody ever paid 90%, and furthermore the rich paid less of a burden then than they do today. Why? The tax system worked a lot differently then. It was the top marginal rate on an income above $300,000 for single, $400,000 for married. In order to effectively be paying 90%, they had to make over $2 million per year. Keep in mind that that kind of money was practically unheard of during that time.

Even if you adjust for inflation, you'll find less people making that amount then than there are today, mainly because all economies were much smaller, there was less money to be made, and overall there was much less wealth that even existed to begin with (and yes, the amount of "wealth" does increase as economies grow, which means there's more to go around.)

Bottom line: Today the rich DO pay a higher portion of taxes than they did then, even when adjusted for inflation. I'll let an investment broker do the explaining here:

In 1958, approximately two million filers (4.4% of all taxpayers) earned the $12,000 or more for married couples needed to face marginal rates as high as 30%. These Americans paid about 35% of all income taxes. And now? In 2010, 3.9 million taxpayers (2.75% of all taxpayers) were subjected to rates that were 33% or higher. These Americans—many of whom would hardly call themselves wealthy—reported an adjusted gross income of $209,000 or higher, and they paid 49.7% of all income taxes.

In contrast, the share of taxes paid by the bottom two-thirds of taxpayers has fallen dramatically over the same period. In 1958, these Americans accounted for 41.3% of adjusted gross income and paid 29% of all federal taxes. By 2010, their share of adjusted gross income had fallen to 22.5%. But their share of taxes paid fell far more dramatically—to 6.7%. The 77% decline represents the single biggest difference in the way the tax burden is shared in this country since the late 1950s.

http://online.wsj.com/news/art...

So you see, even though the top marginal rate was higher back then, the rich paid LESS taxes than they do today. So stop with this Michael Moore bullshit (sorry, just that 90% figure gets thrown around so often, but it doesn't mean what the typical person thinks it would mean; as is typical in Michael Moore fashion.)

Have a nice day.

Re: Alternative Minimum Tax

[pepty]

You don't have any understanding of what is going on here shitbird. Read something before posting. Google is following the law

Some countries (I don't know if France is one) have tax laws stating that if transactions are structured in a particular manner for no reason other than to avoid taxation, the tax avoidance scheme is void. Problem is, laws like those are extremely difficult to enforce effectively and consistently.