The publisher, like many other companies, reduces its tax bill by sending revenue through subsidiaries in countries that charge less tax. It has offices in countries including Malta, Barbados and Bermuda - the latter of which has no staff.
The Netherlands-based subsidiary, Activision Blizzard International B.V., manages rights and distribution outside of the US. But it doesn't make much of a profit - nor other local subsidiaries such as the UK - because it pays royalties to offshore companies in tax havens such as ATVI.C.V. (Bermuda) and ATVI International SRL (Barbados).
The report claims that between 2013 and 2017, Activision Blizzard International B.V. paid out €5 billion in royalties. In 2017, that company made profits before tax of €55.6m, paying €7.2m in tax. That year, it paid €1.3bn in royalties to other companies.
Activision Blizzard is already under investigation by tax authorities in the UK, France and Sweden over alleged transfer pricing irregularities and is facing a potential bill of over $1.1bn in back taxes and penalties.
Only recently did Activision settle a transfer pricing dispute with the IRS following an examination of the company's 2009 to 2011 tax returns. This then saw the firm pay the US $345 million in unpaid taxes.
In 2018, the French tax authority handed Activision a bill of $652 million after being investigated for a transfer pricing dispute via one of its French subsidiaries for the tax years 2011 to 2013.
PocketGamer.biz has discovered official documents that back up some of the above claims. King is facing tax liabilities of approximately $400 million in Sweden - similar to as previously reported - while one of Activision Blizzard's French subsidiaries faces a $652 million bill.
For its part, the publisher disagrees with both decisions and has said it will "vigorously contest" both of them and believes its tax provisions up to December 31st 2018 are appropriate.
PocketGamer.biz has reached out for comment from the company regarding the report and its ongoing fight against these tax bills.
“Abuse of the UK tax system”
“I expect many players of Candy Crush would be outraged to find that the payments they make though the game are sent to a company in Malta, even though King, the Activision company behind the game, is managed from London,” said TaxWatch director George Turner.
“The UK Government is aware that this kind of structure is an abuse of the UK tax system, and introduced new legislation in 2018 to make the UK sourced element of these royalty payments subject to income tax in the UK. However, for some unknown reason the government have excluded payments made to a number of tax havens, including Barbados, ensuring that the new rules will be almost completely ineffective.
“The government needs to change the rules to close down the loopholes they left in the original legislation, and end these royalty based tax avoidance schemes once and for all.”
TaxWatch UK recently released a report on Grand Theft Auto creators Rockstar, which claims the firm hasn’t paid corporation tax in the UK for 10 years.