In 2019, VMware International Unlimited Company (VMIUC) looked like a textbook Irish subsidiary of a successful U.S. tech multinational. Based in Cork and then owned by Dell Technologies, it recorded $4.5 billion in annual revenue, $1.6 billion in gross profit, and paid Irish corporate tax in full. Its tax payments ranged between $43 million and $92 million annually. It had no long-term debt and carried no intangible assets on its books.
Then came 2020, and with it, a financial transformation that turned a profitable software business into a loss-making tax vehicle.
That year, VMIUC acquired global commercial rights to VMware’s intellectual property from its parent, VMware Bermuda Unlimited Company. Although incorporated in Ireland, the parent company was tax resident in Bermuda, the former destination for profits under the now-retired “double Irish” structure.
In the post-double Irish era, the profits couldn’t stay offshore. When the rights to VMware’s IP were onshored to Ireland, the income streams had to come with it. The result was a sharp surge in intangible assets on VMIUC’s balance sheet.
Almost overnight, VMware International Unlimited Company booked $39 billion in intangible assets — the result of a colossal intra-group IP transfer. It was an internal accounting move with very real tax consequences. For those who enjoy cocktail party stats: that’s a 228 million percent increase in a single year.
To fund the $38.9 billion IP move, VMIUC received a $9.3 billion equity injection from its Bermuda parent and took on $27 billion in intra-group debt, all internal to the VMware multi-jurisdictional corporate group (MJG) structure. The strategy followed what many now call the “green jersey” playbook. It issued debt to itself to acquire its own IP, booked the licence as a capital asset, and then used amortisation and interest deductions to erode its taxable income.
On paper, this was a corporate restructuring. In practice, it was a tax manoeuvre.
Ireland’s generous capital allowances regime allows VMIUC to amortise the $39 billion over time, potentially up to 30 years. Beginning in 2020, the company claimed annual deductions starting close to $1 billion, rising to $1.4 billion. It also paid more than $1 billion each year in interest on the internal loans used to finance the IP transaction.
Combined, these deductions were sufficient to eliminate its taxable profits.
Meanwhile, the business itself continued to grow. By 2023, VMIUC’s revenue had risen to $6.4 billion, and gross profit had nearly doubled compared to 2014 – from $1.4 billion to almost $3.5 billion. But in the accounts, VMIUC appeared to be deeply unprofitable. From 2020 to 2023, it has reported annual pre-tax losses ranging from $829 million to $1.57 billion. With its tax base effectively erased, VMIUC not only ceased paying corporate tax. It began accumulating tax credits, worth $101 million in 2023 alone.
That same year, Broadcom acquired VMware. The deal included VMIUC, along with the global rights to monetise VMware’s IP. The legal ownership of the intellectual property remained in the United States, split between Broadcom Inc. and VMware LLC. However, the commercial rights stayed in Ireland, which are presently booked as $35.8 billion in intangible assets on VMIUC’s balance sheet.
Our analysis, using historical IP data from Orbis, shows that VMIUC holds no patents. But since 2020, it has remained consistently in the top 5 intangible asset owners in Ireland. Broadcom’s actual patents and intellectual property are concentrated in the United States and Singapore. What the Irish entity holds is most likely an exclusive economic licence: the right to exploit VMware’s software worldwide. This is not a legal title, but under Irish tax law it qualifies as an intangible asset, and a powerful one.
The strategy rests on a deceptively simple mechanism: one IP, two balance sheets. This is the politics of accounting: converting commercial IP rights into tax-deductible assets. These intangible assets are notoriously difficult to value, allowing significant discretion in how they are priced and reported. This allows all sorts of tax games to played around transfer pricing.
This dual treatment of intellectual property is central to understanding how profit shifting operates in modern global capitalism. The rights to monetise VMware’s IP are located in Ireland. Global software revenues pass through VMIUC’s 40 subsidiaries worldwide. But because Irish law permits extensive amortisation and interest deductions on self-acquired intangible assets, companies can systematically eliminate taxable income.
This is the post-double Irish playbook in action. U.S. multinationals have pivoted to its successor, the “green jersey” structure: the Irish entity owns the IP, earns licensing income, but interest and amortisation strip taxable profit. It encourages companies to onshore IP commercial rights into Ireland, and then offset the resulting income with internal financial charges. In some cases, like Microsoft and Apple, a significant portion of income remains taxable in Ireland. In others, like VMware, the outcome is near-total tax disappearance.
This structural advantage of big business reinforces the concentration of market power and corporate wealth.
VMIUC hasn’t hidden its legal-accounting strategy. The filings are clear. The structure is lawful. But the effect is unmistakable. In 2019, the company was profitable and taxable. From 2020, it has been deliberately engineered into a loss-maker for the wider corporate group. This isn’t operational failure; it’s financial design. The intellectual property remains in the United States. The deductions are booked in Ireland. And somewhere in between, a large slice of the tax liability disappears.
One IP. Two balance sheets.
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