Since NortonLifeLock culled a subsidiary worth over $8bn in its former double Irish-Jersey tax structure, as reported by The Currency at the end of last month, the US group formerly known as Symantec has reported a series of share transfers confirming the completion of its corporate consolidation for business outside America into a central Irish company.

Documents received by the CRO on July 1, but reporting transactions from March to November 2018, show that trading companies with a combined book value of €1.2 billion, are now wholly owned by Symantec Technologies (Ireland) Ltd in Ballicoolin business park in Dublin.

Symantec Technologies (Ireland) Ltd funded all transactions by issuing new shares – effectively paper moves to formalise transfers of ownership between related companies all belonging to the same group.

These subsidiaries were previously held through three holding companies operating across Ireland and the Channel island of Jersey – a structure that NortonLifeLock has been decommissioning as tax reform here and the US removed advantages from locating profits and intellectual property rights between Ireland and low-tax offshore jurisdictions.

These are the entities conducting marketing activities in the online security giant’s main markets, but not the conduits for financial flows and software licensing once they have won over customers. 

For example, the latest  customer agreement applying to the far east states: “NortonLifeLock Ireland Limited is the contracting NortonLifeLock entity for Asia Pacific and Japan.” A note for Japanese customers specifies that the Irish company became the licence holder for their software on March 29, 2018. It is also the issuer of the group’s terms of sale for customers in Europe, Middle East and Africa. 

While NortonLifeLock Ireland Ltd directly sold €1 billion worth of software to customers according to its latest annual accounts to the end of March 2019, it recorded a cost of sale charge of €609.5 million – a close match for the $608 million generated in royalty income by Symantec Technology (Ireland) Ltd during its first year in existence as the group’s Irish-based intellectual property centre.

Ready for the green jersey

Over the past four months, The Currency has tracked company filings revealing the full extent of NortonLifeLock’s multi-billion onshoring of its non-American business to Ireland since 2018. First, I showed how the group had created Symantec Technology (Ireland) Ltd in February of that year and conducted a complex series of transactions to move over $7.2 billion worth of intellectual property assets into the company, financed through inter-company loans. 

I then reported the liquidation of the Irish-registered, Jersey-resident holding company previously at the centre of Symantec’s double Irish tax structure, with $8.3 billion in net assets.

Finally, the latest filings detailing the transfer of ownership for subsidiaries with a book value of $1.4 billion to Symantec Technology (Ireland) Ltd complete the picture and close the gap between the two figures above – the $300 million adjustment likely resulting from a combination of overlap between the multiple entities created and merged over the past two years, depreciation of assets occurring during the period and exchange rate fluctuations.

The old Symantec, renamed NortonLifeLock last year following the sale of its enterprise division to Broadcom, is fully set up to benefit from the so-called green jersey tax arrangement, with Symantec Technology (Ireland) Ltd offsetting the benefits of capital allowances on intangible assets against NortonLifeLock Ireland Ltd’s profits from international software sales under Irish tax rules.