But HMRC and Google’s lawyers were unsure whether the diverted profits tax would apply to its UK operations. In the end, they decided it did not. The company also did not have to concede that Google’s Irish business had a “permanent establishment” — a taxable presence — in the UK. After its lengthy audit, HMRC ran its numbers and found Google owed just £130m.
That’s what it owes under the law as it is. No sweetheart deal.