Apple Australia is owned by Apple Ireland

[barryqwalsh]

APRIL 2015

Tax Avoidance Hearing: Australian Senate

Under questioning from independent senator Nick Xenophon, Mr King said Apple Australia is owned by Apple Ireland, which has a relatively low corporate tax rate. But he admitted he had never been on a business trip to Ireland.

Apple had turnover of $6 billion in Australia last year and paid $80 million in tax.

Mr King was unable to say how much of the money paid by Australian consumers buying Apple products went offshore.

"I find it extraordinary you can't answer that," Senator Xenophon said.

Senator Matthew Canavan purchased a $16.99 album on iTunes during the hearing and asked how much of that price would have been taxable income.

Mr King took the question on notice.



Tax avoidance hearing: Google, Microsoft and Apple tell Senate committee they fully comply with Australian laws

 

[Eloy]

Apple uses Ireland to operate a tax avoidance scam. All Apple's world profits (except from the USA) are recorded by Apple's Irish company but only as little as 0.005% of these profits are taxed at the Irish corporate tax rate of 12.5%. The other 99.995% of profits then go to another of Apple's companies which are not taxed. Since this practice was identified by the Commission on Competition of the European Union as illegal state aid to Apple by the Irish government, the Irish are required to bill Apple for €13,000,000,000 plus up to €6,000,000,000 in interest.

 

[Andylusion]

Apple uses Ireland to operate a tax avoidance scam. All Apple's world profits (except from the USA) are recorded by Apple's Irish company but only as little as 0.005% of these profits are taxed at the Irish corporate tax rate of 12.5%. The other 99.995% of profits then go to another of Apple's companies which are not taxed. Since this practice was identified by the Commission on Competition of the European Union as illegal state aid to Apple by the Irish government, the Irish are required to bill Apple for €13,000,000,000 plus up to €6,000,000,000 in interest.

All true, except it's not a scam. It's completely legal, and by the law. Ireland directly offered Apple a deal... which they have the right as a sovereign country to do.

I think they should not have.... but then, if they didn't, Apple would not have incorporated there, and they would have gotten zero tax revenue.

It's not a scam though. I don't understand why you jack up taxes on companies, and companies avoid the tax, and you act surprised.

If McDonald jacks up the price of a burger.... you avoid McDonalds. If your cell phone company, jacks up the cost of your cell phone, you find another service provider. If the oil change company jacks up the cost of doing an oil change... you find someplace cheaper to do the oil change.

The people who start companies, and open businesses.... are just people. Like you. Why do you expect them to act differently.... THAN YOU DO?

I know people who donate to charity, and take out mortgages on a property, in order to get the tax deduction, to reduce their tax bill. Why is it perfectly fine for *YOU* to take every deduction to avoid as much tax as you possibly can.... and yet when Apple does EXACTLY THE SAME THING.... you call it a scam?

I just don't understand the hypocrisy here.

 

[barryqwalsh]

There wasn't a hipster beard or T-shirt to be seen when representatives from tech giants Google, Apple and Microsoft were quizzed by a Senate committee about their tax arrangements in Sydney on Wednesday.

Apple's Tony King, Google's Maile Carnegie and Microsoft's Bill Sample each said their company complied fully with Australian tax laws and drew attention to the way Australia benefited from their products and services. Mr King said Apple believed in "leaving the world a better place" and Ms Carnegie said she was "proud of Google's contribution to Australia".

But things got testy when Greens leader Senator Christine Milne asked the executives about the "double Irish sandwich with Dutch associations" – a nickname given to one of the complex tax minimisation schemes multinationals are accused of using.


Tax avoidance hearing: Google, Microsoft and Apple tell Senate committee they fully comply with Australian laws

 

[Eloy]

Apple uses Ireland to operate a tax avoidance scam. All Apple's world profits (except from the USA) are recorded by Apple's Irish company but only as little as 0.005% of these profits are taxed at the Irish corporate tax rate of 12.5%. The other 99.995% of profits then go to another of Apple's companies which are not taxed. Since this practice was identified by the Commission on Competition of the European Union as illegal state aid to Apple by the Irish government, the Irish are required to bill Apple for €13,000,000,000 plus up to €6,000,000,000 in interest.

All true, except it's not a scam. It's completely legal, and by the law. Ireland directly offered Apple a deal... which they have the right as a sovereign country to do.

I think they should not have.... but then, if they didn't, Apple would not have incorporated there, and they would have gotten zero tax revenue. ...

The Irish government holds the same view as yourself and intend to use taxpayers money to fight the European Commission's finding in court. They will lose. Even the Irish European Commissioner voted with the unanimous decision of the Commission. It is a scam because the Irish government made a sweetheart deal with Apple in return for locating its offices there and no such deal was offered to any other corporation. This is illegal in European Union law which forbids the state to aid one company by not charging the 12.5% corporation tax which other companies must pay and instead making an exception for Apple. 99.995% of Apple's profits were taxed nowhere. This is manifestly a scam. You will see that the Commission is right and the Irish government will be required to take the €13bn against their will. What a joke!

 

[xband]

Eire is independent and no longer under the British Monarchy. Eire needs investment money and may or may not be an illegal tax haven. If Apple is in Eire and pays no taxes then the Irish like apple pie.

 

[Eloy]

Eire is independent and no longer under the British Monarchy. Eire needs investment money and may or may not be an illegal tax haven. If Apple is in Eire and pays no taxes then the Irish like apple pie.

Ireland is not independent of the European Union and is treaty-bound to honor EU fair competition law.

 

[xband]

Eire is independent and no longer under the British Monarchy. Eire needs investment money and may or may not be an illegal tax haven. If Apple is in Eire and pays no taxes then the Irish like apple pie.

Ireland is not independent of the European Union and is treaty-bound to honor EU fair competition law.

Eire screwed up big time by joining the EU which I did not know. I have one ancestor from Cork and people I have met from Cork are opinionated.

 

[Eloy]

Eire is independent and no longer under the British Monarchy. Eire needs investment money and may or may not be an illegal tax haven. If Apple is in Eire and pays no taxes then the Irish like apple pie.

Ireland is not independent of the European Union and is treaty-bound to honor EU fair competition law.

Eire screwed up big time by joining the EU which I did not know. I have one ancestor from Cork and people I have met from Cork are opinionated.

Most of Ireland's exports in 1961 went to Britain. Since Britain that year applied to join the Common Market, Ireland had little choice but to join also or else suffer a tariff wall for all its dairy and live cattle trade.

 

[xband]

Eire is independent and no longer under the British Monarchy. Eire needs investment money and may or may not be an illegal tax haven. If Apple is in Eire and pays no taxes then the Irish like apple pie.

Ireland is not independent of the European Union and is treaty-bound to honor EU fair competition law.

Eire screwed up big time by joining the EU which I did not know. I have one ancestor from Cork and people I have met from Cork are opinionated.

Most of Ireland's exports in 1961 went to Britain. Since Britain that year applied to join the Common Market, Ireland had little choice but to join also or else suffer a tariff wall for all its dairy and live cattle trade.

You insist using Ireland (English word) rather than Eire. I was born on Lake Erie which is a misspelling of Eire.

 

[Eloy]

Eire is independent and no longer under the British Monarchy. Eire needs investment money and may or may not be an illegal tax haven. If Apple is in Eire and pays no taxes then the Irish like apple pie.

Ireland is not independent of the European Union and is treaty-bound to honor EU fair competition law.

Eire screwed up big time by joining the EU which I did not know. I have one ancestor from Cork and people I have met from Cork are opinionated.

Most of Ireland's exports in 1961 went to Britain. Since Britain that year applied to join the Common Market, Ireland had little choice but to join also or else suffer a tariff wall for all its dairy and live cattle trade.

You insist using Ireland (English word) rather than Eire. I was born on Lake Erie which is a misspelling of Eire.

But we are writing in English. I think you will find nobody in Ireland, unless they are speaking Gaelic, refers to the country as Éire.

 

[xband]

Eire is independent and no longer under the British Monarchy. Eire needs investment money and may or may not be an illegal tax haven. If Apple is in Eire and pays no taxes then the Irish like apple pie.

Ireland is not independent of the European Union and is treaty-bound to honor EU fair competition law.

Eire screwed up big time by joining the EU which I did not know. I have one ancestor from Cork and people I have met from Cork are opinionated.

Most of Ireland's exports in 1961 went to Britain. Since Britain that year applied to join the Common Market, Ireland had little choice but to join also or else suffer a tariff wall for all its dairy and live cattle trade.

You insist using Ireland (English word) rather than Eire. I was born on Lake Erie which is a misspelling of Eire.

But we are writing in English. I think you will find nobody in Ireland, unless they are speaking Gaelic, refers to the country as Éire.

You know what I mean without delving into semantics. Eire is the ancient word for Ireland and think that ancient word gives the Irish pride. Nobody has been beaten down by the English worse than the Irish except for the Scots. Harper is a Scot name and the maiden name of my mother.

 

[Eloy]

Ireland is not independent of the European Union and is treaty-bound to honor EU fair competition law.

Eire screwed up big time by joining the EU which I did not know. I have one ancestor from Cork and people I have met from Cork are opinionated.

Most of Ireland's exports in 1961 went to Britain. Since Britain that year applied to join the Common Market, Ireland had little choice but to join also or else suffer a tariff wall for all its dairy and live cattle trade.

You insist using Ireland (English word) rather than Eire. I was born on Lake Erie which is a misspelling of Eire.

But we are writing in English. I think you will find nobody in Ireland, unless they are speaking Gaelic, refers to the country as Éire.

You know what I mean without delving into semantics. Eire is the ancient word for Ireland and think that ancient word gives the Irish pride. Nobody has been beaten down by the English worse than the Irish except for the Scots. Harper is a Scot name and the maiden name of my mother.

Yes, I know what you mean.

 

[Andylusion]

Apple uses Ireland to operate a tax avoidance scam. All Apple's world profits (except from the USA) are recorded by Apple's Irish company but only as little as 0.005% of these profits are taxed at the Irish corporate tax rate of 12.5%. The other 99.995% of profits then go to another of Apple's companies which are not taxed. Since this practice was identified by the Commission on Competition of the European Union as illegal state aid to Apple by the Irish government, the Irish are required to bill Apple for €13,000,000,000 plus up to €6,000,000,000 in interest.

All true, except it's not a scam. It's completely legal, and by the law. Ireland directly offered Apple a deal... which they have the right as a sovereign country to do.

I think they should not have.... but then, if they didn't, Apple would not have incorporated there, and they would have gotten zero tax revenue. ...

The Irish government holds the same view as yourself and intend to use taxpayers money to fight the European Commission's finding in court. They will lose. Even the Irish European Commissioner voted with the unanimous decision of the Commission. It is a scam because the Irish government made a sweetheart deal with Apple in return for locating its offices there and no such deal was offered to any other corporation. This is illegal in European Union law which forbids the state to aid one company by not charging the 12.5% corporation tax which other companies must pay and instead making an exception for Apple. 99.995% of Apple's profits were taxed nowhere. This is manifestly a scam. You will see that the Commission is right and the Irish government will be required to take the €13bn against their will. What a joke!

I am finding conflicting information. None seems to come close to your claims.

EU revenue, was only €40 Billion Euros. In which case, you would be right... They have paid about 00.005% of revenue in taxes. That's true. But that's not €40 Billion in profit. That's €40 in Revenue.

According to what I've read, Apple has paid the EU 4% of it's profits in taxes.

Now that's still fairly low, but that is because of how the Irish tax system works. Again the information I've seen is contrary to what you claim. The system Apple has used, is well known, and even has it's own nick-name... the Double Irish Flip. A number of companies take advantage of it.

Indicating it's not a specific aid to a specific company.

Of course there is still some possibility of a hidden arrangement that is exclusive. But even then, that only means that the EU will lose even more revenue. Tim Cook has already said that depending on how this plays out, Apple may pull out of the EU. Not in sales. They will of course keep selling Iphones to whomever they can, but outside of that, they will withdraw their assets and investments in the EU.

Meaning in the short term they'll get the $13 Billion.... Not the EU, but rather Ireland will. But in the long term, billions of Euros will be removed from the EU, and thousands of jobs will be lost, and the tax revenue from those jobs will be lost.

And if Apple pulls out, so will many other companies worried over getting nailed with a heavy tax penalty. The EU could lose hundreds of billions of Euros from this one terrible move. Especially right now, when they need foreign investment and jobs the most.

This is a very bad plan, that if not handled carefully, could have a long term negative impact.

 

[Eloy]

Apple uses Ireland to operate a tax avoidance scam. All Apple's world profits (except from the USA) are recorded by Apple's Irish company but only as little as 0.005% of these profits are taxed at the Irish corporate tax rate of 12.5%. The other 99.995% of profits then go to another of Apple's companies which are not taxed. Since this practice was identified by the Commission on Competition of the European Union as illegal state aid to Apple by the Irish government, the Irish are required to bill Apple for €13,000,000,000 plus up to €6,000,000,000 in interest.

All true, except it's not a scam. It's completely legal, and by the law. Ireland directly offered Apple a deal... which they have the right as a sovereign country to do.

I think they should not have.... but then, if they didn't, Apple would not have incorporated there, and they would have gotten zero tax revenue. ...

The Irish government holds the same view as yourself and intend to use taxpayers money to fight the European Commission's finding in court. They will lose. Even the Irish European Commissioner voted with the unanimous decision of the Commission. It is a scam because the Irish government made a sweetheart deal with Apple in return for locating its offices there and no such deal was offered to any other corporation. This is illegal in European Union law which forbids the state to aid one company by not charging the 12.5% corporation tax which other companies must pay and instead making an exception for Apple. 99.995% of Apple's profits were taxed nowhere. This is manifestly a scam. You will see that the Commission is right and the Irish government will be required to take the €13bn against their will. What a joke!

I am finding conflicting information. None seems to come close to your claims.

EU revenue, was only €40 Billion Euros. In which case, you would be right... They have paid about 00.005% of revenue in taxes. That's true. But that's not €40 Billion in profit. That's €40 in Revenue.

According to what I've read, Apple has paid the EU 4% of it's profits in taxes.

Now that's still fairly low, but that is because of how the Irish tax system works. Again the information I've seen is contrary to what you claim. The system Apple has used, is well known, and even has it's own nick-name... the Double Irish Flip. A number of companies take advantage of it.

Indicating it's not a specific aid to a specific company.

Of course there is still some possibility of a hidden arrangement that is exclusive. But even then, that only means that the EU will lose even more revenue. Tim Cook has already said that depending on how this plays out, Apple may pull out of the EU. Not in sales. They will of course keep selling Iphones to whomever they can, but outside of that, they will withdraw their assets and investments in the EU.

Meaning in the short term they'll get the $13 Billion.... Not the EU, but rather Ireland will. But in the long term, billions of Euros will be removed from the EU, and thousands of jobs will be lost, and the tax revenue from those jobs will be lost.

And if Apple pulls out, so will many other companies worried over getting nailed with a heavy tax penalty. The EU could lose hundreds of billions of Euros from this one terrible move. Especially right now, when they need foreign investment and jobs the most.

This is a very bad plan, that if not handled carefully, could have a long term negative impact.

We seem to be reading different newspapers. What you call "the Double Irish Flip" where the Irish government allowed a company registered in Ireland to receive all the profits accrued from states on the European Union (and the rest of the world) but the company was allowed to register another so-called head office in Ireland, with no address or employees. Because two companies exist, it is called the "double Irish" arrangement. It is an illegal scam because the second company is actually a bank account into which Apple was placing 99.995% of its profits tax free. Since the official and perfectly legal corporation tax in Ireland is 12.5%, the Irish government has been facilitating tax avoidance over the years to the tune of €13bn plus interest. By allowing this arrangement, Ireland has been a tax haven. Since other corporations in Ireland are paying 12.5% in tax, the European Commission has found that Ireland has been giving a lower rate of tax to Apple, thereby violating the European Union's fair competition law. If, as you say, other corporations have been getting similar deals from the Irish government, the Irish people would like to know who they are and to have the books examined,

 

[Andylusion]

Apple uses Ireland to operate a tax avoidance scam. All Apple's world profits (except from the USA) are recorded by Apple's Irish company but only as little as 0.005% of these profits are taxed at the Irish corporate tax rate of 12.5%. The other 99.995% of profits then go to another of Apple's companies which are not taxed. Since this practice was identified by the Commission on Competition of the European Union as illegal state aid to Apple by the Irish government, the Irish are required to bill Apple for €13,000,000,000 plus up to €6,000,000,000 in interest.

All true, except it's not a scam. It's completely legal, and by the law. Ireland directly offered Apple a deal... which they have the right as a sovereign country to do.

I think they should not have.... but then, if they didn't, Apple would not have incorporated there, and they would have gotten zero tax revenue. ...

The Irish government holds the same view as yourself and intend to use taxpayers money to fight the European Commission's finding in court. They will lose. Even the Irish European Commissioner voted with the unanimous decision of the Commission. It is a scam because the Irish government made a sweetheart deal with Apple in return for locating its offices there and no such deal was offered to any other corporation. This is illegal in European Union law which forbids the state to aid one company by not charging the 12.5% corporation tax which other companies must pay and instead making an exception for Apple. 99.995% of Apple's profits were taxed nowhere. This is manifestly a scam. You will see that the Commission is right and the Irish government will be required to take the €13bn against their will. What a joke!

I am finding conflicting information. None seems to come close to your claims.

EU revenue, was only €40 Billion Euros. In which case, you would be right... They have paid about 00.005% of revenue in taxes. That's true. But that's not €40 Billion in profit. That's €40 in Revenue.

According to what I've read, Apple has paid the EU 4% of it's profits in taxes.

Now that's still fairly low, but that is because of how the Irish tax system works. Again the information I've seen is contrary to what you claim. The system Apple has used, is well known, and even has it's own nick-name... the Double Irish Flip. A number of companies take advantage of it.

Indicating it's not a specific aid to a specific company.

Of course there is still some possibility of a hidden arrangement that is exclusive. But even then, that only means that the EU will lose even more revenue. Tim Cook has already said that depending on how this plays out, Apple may pull out of the EU. Not in sales. They will of course keep selling Iphones to whomever they can, but outside of that, they will withdraw their assets and investments in the EU.

Meaning in the short term they'll get the $13 Billion.... Not the EU, but rather Ireland will. But in the long term, billions of Euros will be removed from the EU, and thousands of jobs will be lost, and the tax revenue from those jobs will be lost.

And if Apple pulls out, so will many other companies worried over getting nailed with a heavy tax penalty. The EU could lose hundreds of billions of Euros from this one terrible move. Especially right now, when they need foreign investment and jobs the most.

This is a very bad plan, that if not handled carefully, could have a long term negative impact.

We seem to be reading different newspapers. What you call "the Double Irish Flip" where the Irish government allowed a company registered in Ireland to receive all the profits accrued from states on the European Union (and the rest of the world) but the company was allowed to register another so-called head office in Ireland, with no address or employees. Because two companies exist, it is called the "double Irish" arrangement. It is an illegal scam because the second company is actually a bank account into which Apple was placing 99.995% of its profits tax free. Since the official and perfectly legal corporation tax in Ireland is 12.5%, the Irish government has been facilitating tax avoidance over the years to the tune of €13bn plus interest. By allowing this arrangement, Ireland has been a tax haven. Since other corporations in Ireland are paying 12.5% in tax, the European Commission has found that Ireland has been giving a lower rate of tax to Apple, thereby violating the European Union's fair competition law. If, as you say, other corporations have been getting similar deals from the Irish government, the Irish people would like to know who they are and to have the books examined,

First off.... you seem to be implying that only under Irish law, can a company move profits around from other EU States. As if this was something 'special' about Ireland law.

This is not true. Any company, can create a subsidiary, and move profits either to the subsidiary, or from that subsidiary, and there is absolutely nothing any government can do about. This is universally true, in every country on the planet.

Let us pretend for a moment, that you owned a lemonade company. But you had a subsidiary name Lemonade Plus that actually made the drink, and another subsidiary named Lemonade Retail that sold the drink.

Because you own both the company that makes the Lemonade, and the company which sells the Lemonade, you can move the profits to either company. And there is nothing anyone, or any government can do about it.

If Lemon Plus is in the law tax area, you have it make the Lemonade, and market up the price, and sell it to Lemon Retail at the market. Lemon Retail sells the Lemonade at cost. Lemon Plus records the profits, and Lemon Retail records zero profit.

However, if Lemon Plus is in a high tax area, and Lemon Retail is in the low tax area... you just have Lemon Plus make the lemonade, and sell it at cost. Then Lemon Retail buys the lemonade and marks up the price for sale.

Lemon Plus records zero profit, and Lemon Retail records all the profits.

You can move the profits around at will. You could have the profits switched back and fourth every month, if you wanted to. And there is nothing anyone can do about it.

It's not a "special deal" from Ireland. Unless you do away with freedom, and nationalize everything.... any company can do this, from any country around the entire globe.

They do have some "Transfer Pricing" rules, and Ireland has put in place these rules over the past 10 years. But the fact is, even those rules are not all that effective, because you have to rely on the company to file the estimates of what the transfer pricing should be. Why? Because product moved between subsidiaries isn't on the general market. Thus there is no market to base that price on. You have no choice but to have the company tell you what it should be.

Now it is true that for a long time Ireland had a system where a company could incorporate in Ireland, without being a resident of Ireland.

I will grant you that. And I will also admit that Apple in the 1980s, had that arrangement, where they were incorporated, but not a tax resident, meaning they avoided most of Ireland's corporate taxes, while at the same time, using Ireland to pay low taxes on their profits. Thus, they had a corporation with no address, and no employees.

That however hasn't been true in decades.

This is Apple Corporate Headquarters, located in Cork Ireland.

This is a real place, with a real address, with real employees. Nearly 5,000 employees work high paying corporate jobs for Apple computer in Ireland.

Real jobs that could be very easily lost. The whole reason Apple invested into Ireland to begin with, was because of the competitive tax rates. If you eliminate the reason for them being there, they could very easily move elsewhere.

And Tim Cook, has already said in no uncertain terms, that if the EU screws this up, they could very well move out of the area.

Lastly, you claimed that other corporations operating in Ireland, are paying 12.5%. This isn't true.

There is no evidence, that Apple has a lower corporate tax rate, or that other corporations have a higher tax rate.

The newspapers you are reading, are ignorant.

The papers are confusing 'effective' tax rates, with the 'stated' tax rate. The stated tax rate is 12.5%. But just like your personal income taxes, the stated rate, and the effective rate, are completely different.

Just like me. I am in a 25% tax bracket. But I have never yet paid 25% of my income in taxes. Why? Deductions. Interest deductions, medical expense deductions, student loan deductions, charitable giving deductions. Three years ago, my income tax was zero. My personal income tax rate, was 0%. I was paid zero.

Does that mean I had some magic special exclusive deal with the United States Federal government? No. It was simply how the tax law is written.

Apple too, has deductions. Ireland, like most countries, has many deductions. For example, all the taxes Apple pays to other countries, are deductible in Ireland. Same is true in the US, by the way. If Apple pays $10 Billion in Europe, and brings the money home, they can deduct $10 Billion from their US tax bill.

Ireland allows deductions for investments in Ireland. Again, another reason Apple invested in Ireland.

And by the way, ALL companies in Ireland benefit from these deductions.

Effective Rates of Corporation Tax in Ireland by Seamus Coffey :: SSRN

This research paper was published by the University of Cork Ireland. Even they found that companies around Ireland rarely paid 12.5% in taxes. The effective tax rate, is much lower, with many companies pay just a few percent of their profits in taxes.

Again... this isn't a special deal with Apple, and no, all other companies are not paying 12.5%. They all pay, more tax, and less tax, depending on the deductions they qualify for.

And this idea that Apple paid only 00.005% in taxes... I doubt it. Ireland itself, said openly they paid 4%. Which is in line with what the research paper from Cork University says.

Again, my argument to you, would be the same as before.

This deal with the EU forcing high taxes on companies, has zero positives, and tons of negatives.

There is no good thing that is going to come from this. You jack up taxes on corporations, and they'll leave. Especially when the only reason they were there to begin with, was for the tax advantages.

What is the win here? More unemployed people? Less investment in your country? Lower growth? Fewer jobs?

What exactly do you think is going to happen as a result of this, that is going to be 'good'?

 

[Eloy]

Apple uses Ireland to operate a tax avoidance scam. All Apple's world profits (except from the USA) are recorded by Apple's Irish company but only as little as 0.005% of these profits are taxed at the Irish corporate tax rate of 12.5%. The other 99.995% of profits then go to another of Apple's companies which are not taxed. Since this practice was identified by the Commission on Competition of the European Union as illegal state aid to Apple by the Irish government, the Irish are required to bill Apple for €13,000,000,000 plus up to €6,000,000,000 in interest.

All true, except it's not a scam. It's completely legal, and by the law. Ireland directly offered Apple a deal... which they have the right as a sovereign country to do.

I think they should not have.... but then, if they didn't, Apple would not have incorporated there, and they would have gotten zero tax revenue. ...

The Irish government holds the same view as yourself and intend to use taxpayers money to fight the European Commission's finding in court. They will lose. Even the Irish European Commissioner voted with the unanimous decision of the Commission. It is a scam because the Irish government made a sweetheart deal with Apple in return for locating its offices there and no such deal was offered to any other corporation. This is illegal in European Union law which forbids the state to aid one company by not charging the 12.5% corporation tax which other companies must pay and instead making an exception for Apple. 99.995% of Apple's profits were taxed nowhere. This is manifestly a scam. You will see that the Commission is right and the Irish government will be required to take the €13bn against their will. What a joke!

I am finding conflicting information. None seems to come close to your claims.

EU revenue, was only €40 Billion Euros. In which case, you would be right... They have paid about 00.005% of revenue in taxes. That's true. But that's not €40 Billion in profit. That's €40 in Revenue.

According to what I've read, Apple has paid the EU 4% of it's profits in taxes.

Now that's still fairly low, but that is because of how the Irish tax system works. Again the information I've seen is contrary to what you claim. The system Apple has used, is well known, and even has it's own nick-name... the Double Irish Flip. A number of companies take advantage of it.

Indicating it's not a specific aid to a specific company.

Of course there is still some possibility of a hidden arrangement that is exclusive. But even then, that only means that the EU will lose even more revenue. Tim Cook has already said that depending on how this plays out, Apple may pull out of the EU. Not in sales. They will of course keep selling Iphones to whomever they can, but outside of that, they will withdraw their assets and investments in the EU.

Meaning in the short term they'll get the $13 Billion.... Not the EU, but rather Ireland will. But in the long term, billions of Euros will be removed from the EU, and thousands of jobs will be lost, and the tax revenue from those jobs will be lost.

And if Apple pulls out, so will many other companies worried over getting nailed with a heavy tax penalty. The EU could lose hundreds of billions of Euros from this one terrible move. Especially right now, when they need foreign investment and jobs the most.

This is a very bad plan, that if not handled carefully, could have a long term negative impact.

We seem to be reading different newspapers. What you call "the Double Irish Flip" where the Irish government allowed a company registered in Ireland to receive all the profits accrued from states on the European Union (and the rest of the world) but the company was allowed to register another so-called head office in Ireland, with no address or employees. Because two companies exist, it is called the "double Irish" arrangement. It is an illegal scam because the second company is actually a bank account into which Apple was placing 99.995% of its profits tax free. Since the official and perfectly legal corporation tax in Ireland is 12.5%, the Irish government has been facilitating tax avoidance over the years to the tune of €13bn plus interest. By allowing this arrangement, Ireland has been a tax haven. Since other corporations in Ireland are paying 12.5% in tax, the European Commission has found that Ireland has been giving a lower rate of tax to Apple, thereby violating the European Union's fair competition law. If, as you say, other corporations have been getting similar deals from the Irish government, the Irish people would like to know who they are and to have the books examined,

First off.... you seem to be implying that only under Irish law, can a company move profits around from other EU States. As if this was something 'special' about Ireland law.

This is not true. Any company, can create a subsidiary, and move profits either to the subsidiary, or from that subsidiary, and there is absolutely nothing any government can do about. This is universally true, in every country on the planet.

Let us pretend for a moment, that you owned a lemonade company. But you had a subsidiary name Lemonade Plus that actually made the drink, and another subsidiary named Lemonade Retail that sold the drink.

Because you own both the company that makes the Lemonade, and the company which sells the Lemonade, you can move the profits to either company. And there is nothing anyone, or any government can do about it.

If Lemon Plus is in the law tax area, you have it make the Lemonade, and market up the price, and sell it to Lemon Retail at the market. Lemon Retail sells the Lemonade at cost. Lemon Plus records the profits, and Lemon Retail records zero profit.

However, if Lemon Plus is in a high tax area, and Lemon Retail is in the low tax area... you just have Lemon Plus make the lemonade, and sell it at cost. Then Lemon Retail buys the lemonade and marks up the price for sale.

Lemon Plus records zero profit, and Lemon Retail records all the profits.

You can move the profits around at will. You could have the profits switched back and fourth every month, if you wanted to. And there is nothing anyone can do about it.

It's not a "special deal" from Ireland. Unless you do away with freedom, and nationalize everything.... any company can do this, from any country around the entire globe.

They do have some "Transfer Pricing" rules, and Ireland has put in place these rules over the past 10 years. But the fact is, even those rules are not all that effective, because you have to rely on the company to file the estimates of what the transfer pricing should be. Why? Because product moved between subsidiaries isn't on the general market. Thus there is no market to base that price on. You have no choice but to have the company tell you what it should be.

Now it is true that for a long time Ireland had a system where a company could incorporate in Ireland, without being a resident of Ireland.

I will grant you that. And I will also admit that Apple in the 1980s, had that arrangement, where they were incorporated, but not a tax resident, meaning they avoided most of Ireland's corporate taxes, while at the same time, using Ireland to pay low taxes on their profits. Thus, they had a corporation with no address, and no employees.

That however hasn't been true in decades.

View attachment 89092

This is Apple Corporate Headquarters, located in Cork Ireland.
View attachment 89094
This is a real place, with a real address, with real employees. Nearly 5,000 employees work high paying corporate jobs for Apple computer in Ireland.

Real jobs that could be very easily lost. The whole reason Apple invested into Ireland to begin with, was because of the competitive tax rates. If you eliminate the reason for them being there, they could very easily move elsewhere.

And Tim Cook, has already said in no uncertain terms, that if the EU screws this up, they could very well move out of the area.

Lastly, you claimed that other corporations operating in Ireland, are paying 12.5%. This isn't true.

There is no evidence, that Apple has a lower corporate tax rate, or that other corporations have a higher tax rate.

The newspapers you are reading, are ignorant.

The papers are confusing 'effective' tax rates, with the 'stated' tax rate. The stated tax rate is 12.5%. But just like your personal income taxes, the stated rate, and the effective rate, are completely different.

Just like me. I am in a 25% tax bracket. But I have never yet paid 25% of my income in taxes. Why? Deductions. Interest deductions, medical expense deductions, student loan deductions, charitable giving deductions. Three years ago, my income tax was zero. My personal income tax rate, was 0%. I was paid zero.

Does that mean I had some magic special exclusive deal with the United States Federal government? No. It was simply how the tax law is written.

Apple too, has deductions. Ireland, like most countries, has many deductions. For example, all the taxes Apple pays to other countries, are deductible in Ireland. Same is true in the US, by the way. If Apple pays $10 Billion in Europe, and brings the money home, they can deduct $10 Billion from their US tax bill.

Ireland allows deductions for investments in Ireland. Again, another reason Apple invested in Ireland.

And by the way, ALL companies in Ireland benefit from these deductions.

Effective Rates of Corporation Tax in Ireland by Seamus Coffey :: SSRN

This research paper was published by the University of Cork Ireland. Even they found that companies around Ireland rarely paid 12.5% in taxes. The effective tax rate, is much lower, with many companies pay just a few percent of their profits in taxes.

Again... this isn't a special deal with Apple, and no, all other companies are not paying 12.5%. They all pay, more tax, and less tax, depending on the deductions they qualify for.

And this idea that Apple paid only 00.005% in taxes... I doubt it. Ireland itself, said openly they paid 4%. Which is in line with what the research paper from Cork University says.

Again, my argument to you, would be the same as before.

This deal with the EU forcing high taxes on companies, has zero positives, and tons of negatives.

There is no good thing that is going to come from this. You jack up taxes on corporations, and they'll leave. Especially when the only reason they were there to begin with, was for the tax advantages.

What is the win here? More unemployed people? Less investment in your country? Lower growth? Fewer jobs?

What exactly do you think is going to happen as a result of this, that is going to be 'good'?

Forgive me but your gobbledygook is precisely the sort of spiv talk that Apple and its enabler politicians have been saying but they have been caught in their scam of creating a bogus company for the purpose of avoiding tax on profits. Apple is a multi-billion company and their well-remunerated lawyers will lose their case in the European court because everyone knows that their so-called head office does not exist on planet Earth but is holding billions of profits on which no tax was paid. Not only did Ireland facilitate this special deal with Apple while ordinary Irish citizens have been taxed to bail-out the casino bankers and their government has introduced austerity to reimburse speculative bond holders. That the Irish government will now refuse to take the €13bn plus interest which might amount to €19bn and then spend Irish honest taxpayers money to fight this award is both shocking and unethical. Their cheating scheme which allowed Apple to funnel untaxed profits through a nonexistent company registered in Ireland has been found to be against the interests of fair competition and they will lose in court. While Apple can take the hit, Ireland cannot afford to continue as a shameful tax haven whose reputation as an honest place to do business is already in tatters.

 

[Andylusion]

All true, except it's not a scam. It's completely legal, and by the law. Ireland directly offered Apple a deal... which they have the right as a sovereign country to do.

I think they should not have.... but then, if they didn't, Apple would not have incorporated there, and they would have gotten zero tax revenue. ...

The Irish government holds the same view as yourself and intend to use taxpayers money to fight the European Commission's finding in court. They will lose. Even the Irish European Commissioner voted with the unanimous decision of the Commission. It is a scam because the Irish government made a sweetheart deal with Apple in return for locating its offices there and no such deal was offered to any other corporation. This is illegal in European Union law which forbids the state to aid one company by not charging the 12.5% corporation tax which other companies must pay and instead making an exception for Apple. 99.995% of Apple's profits were taxed nowhere. This is manifestly a scam. You will see that the Commission is right and the Irish government will be required to take the €13bn against their will. What a joke!

I am finding conflicting information. None seems to come close to your claims.

EU revenue, was only €40 Billion Euros. In which case, you would be right... They have paid about 00.005% of revenue in taxes. That's true. But that's not €40 Billion in profit. That's €40 in Revenue.

According to what I've read, Apple has paid the EU 4% of it's profits in taxes.

Now that's still fairly low, but that is because of how the Irish tax system works. Again the information I've seen is contrary to what you claim. The system Apple has used, is well known, and even has it's own nick-name... the Double Irish Flip. A number of companies take advantage of it.

Indicating it's not a specific aid to a specific company.

Of course there is still some possibility of a hidden arrangement that is exclusive. But even then, that only means that the EU will lose even more revenue. Tim Cook has already said that depending on how this plays out, Apple may pull out of the EU. Not in sales. They will of course keep selling Iphones to whomever they can, but outside of that, they will withdraw their assets and investments in the EU.

Meaning in the short term they'll get the $13 Billion.... Not the EU, but rather Ireland will. But in the long term, billions of Euros will be removed from the EU, and thousands of jobs will be lost, and the tax revenue from those jobs will be lost.

And if Apple pulls out, so will many other companies worried over getting nailed with a heavy tax penalty. The EU could lose hundreds of billions of Euros from this one terrible move. Especially right now, when they need foreign investment and jobs the most.

This is a very bad plan, that if not handled carefully, could have a long term negative impact.

We seem to be reading different newspapers. What you call "the Double Irish Flip" where the Irish government allowed a company registered in Ireland to receive all the profits accrued from states on the European Union (and the rest of the world) but the company was allowed to register another so-called head office in Ireland, with no address or employees. Because two companies exist, it is called the "double Irish" arrangement. It is an illegal scam because the second company is actually a bank account into which Apple was placing 99.995% of its profits tax free. Since the official and perfectly legal corporation tax in Ireland is 12.5%, the Irish government has been facilitating tax avoidance over the years to the tune of €13bn plus interest. By allowing this arrangement, Ireland has been a tax haven. Since other corporations in Ireland are paying 12.5% in tax, the European Commission has found that Ireland has been giving a lower rate of tax to Apple, thereby violating the European Union's fair competition law. If, as you say, other corporations have been getting similar deals from the Irish government, the Irish people would like to know who they are and to have the books examined,

First off.... you seem to be implying that only under Irish law, can a company move profits around from other EU States. As if this was something 'special' about Ireland law.

This is not true. Any company, can create a subsidiary, and move profits either to the subsidiary, or from that subsidiary, and there is absolutely nothing any government can do about. This is universally true, in every country on the planet.

Let us pretend for a moment, that you owned a lemonade company. But you had a subsidiary name Lemonade Plus that actually made the drink, and another subsidiary named Lemonade Retail that sold the drink.

Because you own both the company that makes the Lemonade, and the company which sells the Lemonade, you can move the profits to either company. And there is nothing anyone, or any government can do about it.

If Lemon Plus is in the law tax area, you have it make the Lemonade, and market up the price, and sell it to Lemon Retail at the market. Lemon Retail sells the Lemonade at cost. Lemon Plus records the profits, and Lemon Retail records zero profit.

However, if Lemon Plus is in a high tax area, and Lemon Retail is in the low tax area... you just have Lemon Plus make the lemonade, and sell it at cost. Then Lemon Retail buys the lemonade and marks up the price for sale.

Lemon Plus records zero profit, and Lemon Retail records all the profits.

You can move the profits around at will. You could have the profits switched back and fourth every month, if you wanted to. And there is nothing anyone can do about it.

It's not a "special deal" from Ireland. Unless you do away with freedom, and nationalize everything.... any company can do this, from any country around the entire globe.

They do have some "Transfer Pricing" rules, and Ireland has put in place these rules over the past 10 years. But the fact is, even those rules are not all that effective, because you have to rely on the company to file the estimates of what the transfer pricing should be. Why? Because product moved between subsidiaries isn't on the general market. Thus there is no market to base that price on. You have no choice but to have the company tell you what it should be.

Now it is true that for a long time Ireland had a system where a company could incorporate in Ireland, without being a resident of Ireland.

I will grant you that. And I will also admit that Apple in the 1980s, had that arrangement, where they were incorporated, but not a tax resident, meaning they avoided most of Ireland's corporate taxes, while at the same time, using Ireland to pay low taxes on their profits. Thus, they had a corporation with no address, and no employees.

That however hasn't been true in decades.

View attachment 89092

This is Apple Corporate Headquarters, located in Cork Ireland.
View attachment 89094
This is a real place, with a real address, with real employees. Nearly 5,000 employees work high paying corporate jobs for Apple computer in Ireland.

Real jobs that could be very easily lost. The whole reason Apple invested into Ireland to begin with, was because of the competitive tax rates. If you eliminate the reason for them being there, they could very easily move elsewhere.

And Tim Cook, has already said in no uncertain terms, that if the EU screws this up, they could very well move out of the area.

Lastly, you claimed that other corporations operating in Ireland, are paying 12.5%. This isn't true.

There is no evidence, that Apple has a lower corporate tax rate, or that other corporations have a higher tax rate.

The newspapers you are reading, are ignorant.

The papers are confusing 'effective' tax rates, with the 'stated' tax rate. The stated tax rate is 12.5%. But just like your personal income taxes, the stated rate, and the effective rate, are completely different.

Just like me. I am in a 25% tax bracket. But I have never yet paid 25% of my income in taxes. Why? Deductions. Interest deductions, medical expense deductions, student loan deductions, charitable giving deductions. Three years ago, my income tax was zero. My personal income tax rate, was 0%. I was paid zero.

Does that mean I had some magic special exclusive deal with the United States Federal government? No. It was simply how the tax law is written.

Apple too, has deductions. Ireland, like most countries, has many deductions. For example, all the taxes Apple pays to other countries, are deductible in Ireland. Same is true in the US, by the way. If Apple pays $10 Billion in Europe, and brings the money home, they can deduct $10 Billion from their US tax bill.

Ireland allows deductions for investments in Ireland. Again, another reason Apple invested in Ireland.

And by the way, ALL companies in Ireland benefit from these deductions.

Effective Rates of Corporation Tax in Ireland by Seamus Coffey :: SSRN

This research paper was published by the University of Cork Ireland. Even they found that companies around Ireland rarely paid 12.5% in taxes. The effective tax rate, is much lower, with many companies pay just a few percent of their profits in taxes.

Again... this isn't a special deal with Apple, and no, all other companies are not paying 12.5%. They all pay, more tax, and less tax, depending on the deductions they qualify for.

And this idea that Apple paid only 00.005% in taxes... I doubt it. Ireland itself, said openly they paid 4%. Which is in line with what the research paper from Cork University says.

Again, my argument to you, would be the same as before.

This deal with the EU forcing high taxes on companies, has zero positives, and tons of negatives.

There is no good thing that is going to come from this. You jack up taxes on corporations, and they'll leave. Especially when the only reason they were there to begin with, was for the tax advantages.

What is the win here? More unemployed people? Less investment in your country? Lower growth? Fewer jobs?

What exactly do you think is going to happen as a result of this, that is going to be 'good'?

Forgive me but your gobbledygook is precisely the sort of spiv talk that Apple and its enabler politicians have been saying but they have been caught in their scam of creating a bogus company for the purpose of avoiding tax on profits. Apple is a multi-billion company and their well-remunerated lawyers will lose their case in the European court because everyone knows that their so-called head office does not exist on planet Earth but is holding billions of profits on which no tax was paid. Not only did Ireland facilitate this special deal with Apple while ordinary Irish citizens have been taxed to bail-out the casino bankers and their government has introduced austerity to reimburse speculative bond holders. That the Irish government will now refuse to take the €13bn plus interest which might amount to €19bn and then spend Irish honest taxpayers money to fight this award is both shocking and unethical. Their cheating scheme which allowed Apple to funnel untaxed profits through a nonexistent company registered in Ireland has been found to be against the interests of fair competition and they will lose in court. While Apple can take the hit, Ireland cannot afford to continue as a shameful tax haven whose reputation as an honest place to do business is already in tatters.

Well, if you are not willing to learn enough about the topic to speak from an informed perspective... maybe you should be silent.

Second, yes the money which is stored in the corporate account, hasn't be used. So because it has not been used, it has not been taxed either.

IF Apple brought the money to Ireland, and invested, it would be taxed. IF they invested in Europe, it would be taxed. If they invested it in the US, it would be taxed.

It's the same as putting money into your pension. You don't pay the taxes on it, until you take the money out. (at least that's how it works in the US. Could be different there).

Not only did Ireland facilitate this special deal with Apple while ordinary Irish citizens have been taxed to bail-out the casino bankers and their government has introduced austerity to reimburse speculative bond holders.

What has any of this to with Apple? The government of Ireland bailed out the banks. Not Apple.

The people of Ireland voted for their government did they not? Whose fault is this? Not Apple's.

Austerity happens when the government spend more money, than it has. Whose fault is that? Not Apple's.

Why should Apple be punished for the incompetence of the public?

And when Apple closes it's Ireland HQ, and lays off 5,000 people, and stops investing in Ireland, and then they actually pay zero tax.... how will that be a benefit?

Because right now, Apple is paying tons of Ireland taxes. Every executive and employee at Cork, is paying income taxes, and sales taxes, and insurance taxes. Every truck driver they hire to move product is paying sales taxes, and fuel taxes. Every sale they make from Ireland is paying VAT taxes.

Yeah, their corporate tax on profit is low... but they are paying tons of Ireland taxes. How is 'zero' tax when Apple leaves, going to be an improvement? And again Tim Cook said that if the EU pushes ahead with this, they'll move all that money they have in the Ireland economy... out. I guaratee, he won't move it to the EU.

So you are STILL not going to get that money no matter what. Again... what is your "win" here?

While Apple can take the hit, Ireland cannot afford to continue as a shameful tax haven whose reputation as an honest place to do business is already in tatters

So Ireland can afford to lose hundreds of billions and future jobs? Really? They can't afford to not have $13 Billion they never did have.... but they can afford to lose thousands of jobs, and taxes as Apple moves out?

Do you know the phrase "Penny smart, dollar stupid"? Or "short term gain, long term pain"?

Because if Apple takes the hit on this, it won't be just Apple leaving Ireland. It could be dozens of companies, perhaps hundreds of companies leaving Ireland.

Ireland could lose hundreds of billions in lost future growth.

 

[Eloy]

The Irish government holds the same view as yourself and intend to use taxpayers money to fight the European Commission's finding in court. They will lose. Even the Irish European Commissioner voted with the unanimous decision of the Commission. It is a scam because the Irish government made a sweetheart deal with Apple in return for locating its offices there and no such deal was offered to any other corporation. This is illegal in European Union law which forbids the state to aid one company by not charging the 12.5% corporation tax which other companies must pay and instead making an exception for Apple. 99.995% of Apple's profits were taxed nowhere. This is manifestly a scam. You will see that the Commission is right and the Irish government will be required to take the €13bn against their will. What a joke!

I am finding conflicting information. None seems to come close to your claims.

EU revenue, was only €40 Billion Euros. In which case, you would be right... They have paid about 00.005% of revenue in taxes. That's true. But that's not €40 Billion in profit. That's €40 in Revenue.

According to what I've read, Apple has paid the EU 4% of it's profits in taxes.

Now that's still fairly low, but that is because of how the Irish tax system works. Again the information I've seen is contrary to what you claim. The system Apple has used, is well known, and even has it's own nick-name... the Double Irish Flip. A number of companies take advantage of it.

Indicating it's not a specific aid to a specific company.

Of course there is still some possibility of a hidden arrangement that is exclusive. But even then, that only means that the EU will lose even more revenue. Tim Cook has already said that depending on how this plays out, Apple may pull out of the EU. Not in sales. They will of course keep selling Iphones to whomever they can, but outside of that, they will withdraw their assets and investments in the EU.

Meaning in the short term they'll get the $13 Billion.... Not the EU, but rather Ireland will. But in the long term, billions of Euros will be removed from the EU, and thousands of jobs will be lost, and the tax revenue from those jobs will be lost.

And if Apple pulls out, so will many other companies worried over getting nailed with a heavy tax penalty. The EU could lose hundreds of billions of Euros from this one terrible move. Especially right now, when they need foreign investment and jobs the most.

This is a very bad plan, that if not handled carefully, could have a long term negative impact.

We seem to be reading different newspapers. What you call "the Double Irish Flip" where the Irish government allowed a company registered in Ireland to receive all the profits accrued from states on the European Union (and the rest of the world) but the company was allowed to register another so-called head office in Ireland, with no address or employees. Because two companies exist, it is called the "double Irish" arrangement. It is an illegal scam because the second company is actually a bank account into which Apple was placing 99.995% of its profits tax free. Since the official and perfectly legal corporation tax in Ireland is 12.5%, the Irish government has been facilitating tax avoidance over the years to the tune of €13bn plus interest. By allowing this arrangement, Ireland has been a tax haven. Since other corporations in Ireland are paying 12.5% in tax, the European Commission has found that Ireland has been giving a lower rate of tax to Apple, thereby violating the European Union's fair competition law. If, as you say, other corporations have been getting similar deals from the Irish government, the Irish people would like to know who they are and to have the books examined,

First off.... you seem to be implying that only under Irish law, can a company move profits around from other EU States. As if this was something 'special' about Ireland law.

This is not true. Any company, can create a subsidiary, and move profits either to the subsidiary, or from that subsidiary, and there is absolutely nothing any government can do about. This is universally true, in every country on the planet.

Let us pretend for a moment, that you owned a lemonade company. But you had a subsidiary name Lemonade Plus that actually made the drink, and another subsidiary named Lemonade Retail that sold the drink.

Because you own both the company that makes the Lemonade, and the company which sells the Lemonade, you can move the profits to either company. And there is nothing anyone, or any government can do about it.

If Lemon Plus is in the law tax area, you have it make the Lemonade, and market up the price, and sell it to Lemon Retail at the market. Lemon Retail sells the Lemonade at cost. Lemon Plus records the profits, and Lemon Retail records zero profit.

However, if Lemon Plus is in a high tax area, and Lemon Retail is in the low tax area... you just have Lemon Plus make the lemonade, and sell it at cost. Then Lemon Retail buys the lemonade and marks up the price for sale.

Lemon Plus records zero profit, and Lemon Retail records all the profits.

You can move the profits around at will. You could have the profits switched back and fourth every month, if you wanted to. And there is nothing anyone can do about it.

It's not a "special deal" from Ireland. Unless you do away with freedom, and nationalize everything.... any company can do this, from any country around the entire globe.

They do have some "Transfer Pricing" rules, and Ireland has put in place these rules over the past 10 years. But the fact is, even those rules are not all that effective, because you have to rely on the company to file the estimates of what the transfer pricing should be. Why? Because product moved between subsidiaries isn't on the general market. Thus there is no market to base that price on. You have no choice but to have the company tell you what it should be.

Now it is true that for a long time Ireland had a system where a company could incorporate in Ireland, without being a resident of Ireland.

I will grant you that. And I will also admit that Apple in the 1980s, had that arrangement, where they were incorporated, but not a tax resident, meaning they avoided most of Ireland's corporate taxes, while at the same time, using Ireland to pay low taxes on their profits. Thus, they had a corporation with no address, and no employees.

That however hasn't been true in decades.

View attachment 89092

This is Apple Corporate Headquarters, located in Cork Ireland.
View attachment 89094
This is a real place, with a real address, with real employees. Nearly 5,000 employees work high paying corporate jobs for Apple computer in Ireland.

Real jobs that could be very easily lost. The whole reason Apple invested into Ireland to begin with, was because of the competitive tax rates. If you eliminate the reason for them being there, they could very easily move elsewhere.

And Tim Cook, has already said in no uncertain terms, that if the EU screws this up, they could very well move out of the area.

Lastly, you claimed that other corporations operating in Ireland, are paying 12.5%. This isn't true.

There is no evidence, that Apple has a lower corporate tax rate, or that other corporations have a higher tax rate.

The newspapers you are reading, are ignorant.

The papers are confusing 'effective' tax rates, with the 'stated' tax rate. The stated tax rate is 12.5%. But just like your personal income taxes, the stated rate, and the effective rate, are completely different.

Just like me. I am in a 25% tax bracket. But I have never yet paid 25% of my income in taxes. Why? Deductions. Interest deductions, medical expense deductions, student loan deductions, charitable giving deductions. Three years ago, my income tax was zero. My personal income tax rate, was 0%. I was paid zero.

Does that mean I had some magic special exclusive deal with the United States Federal government? No. It was simply how the tax law is written.

Apple too, has deductions. Ireland, like most countries, has many deductions. For example, all the taxes Apple pays to other countries, are deductible in Ireland. Same is true in the US, by the way. If Apple pays $10 Billion in Europe, and brings the money home, they can deduct $10 Billion from their US tax bill.

Ireland allows deductions for investments in Ireland. Again, another reason Apple invested in Ireland.

And by the way, ALL companies in Ireland benefit from these deductions.

Effective Rates of Corporation Tax in Ireland by Seamus Coffey :: SSRN

This research paper was published by the University of Cork Ireland. Even they found that companies around Ireland rarely paid 12.5% in taxes. The effective tax rate, is much lower, with many companies pay just a few percent of their profits in taxes.

Again... this isn't a special deal with Apple, and no, all other companies are not paying 12.5%. They all pay, more tax, and less tax, depending on the deductions they qualify for.

And this idea that Apple paid only 00.005% in taxes... I doubt it. Ireland itself, said openly they paid 4%. Which is in line with what the research paper from Cork University says.

Again, my argument to you, would be the same as before.

This deal with the EU forcing high taxes on companies, has zero positives, and tons of negatives.

There is no good thing that is going to come from this. You jack up taxes on corporations, and they'll leave. Especially when the only reason they were there to begin with, was for the tax advantages.

What is the win here? More unemployed people? Less investment in your country? Lower growth? Fewer jobs?

What exactly do you think is going to happen as a result of this, that is going to be 'good'?

Forgive me but your gobbledygook is precisely the sort of spiv talk that Apple and its enabler politicians have been saying but they have been caught in their scam of creating a bogus company for the purpose of avoiding tax on profits. Apple is a multi-billion company and their well-remunerated lawyers will lose their case in the European court because everyone knows that their so-called head office does not exist on planet Earth but is holding billions of profits on which no tax was paid. Not only did Ireland facilitate this special deal with Apple while ordinary Irish citizens have been taxed to bail-out the casino bankers and their government has introduced austerity to reimburse speculative bond holders. That the Irish government will now refuse to take the €13bn plus interest which might amount to €19bn and then spend Irish honest taxpayers money to fight this award is both shocking and unethical. Their cheating scheme which allowed Apple to funnel untaxed profits through a nonexistent company registered in Ireland has been found to be against the interests of fair competition and they will lose in court. While Apple can take the hit, Ireland cannot afford to continue as a shameful tax haven whose reputation as an honest place to do business is already in tatters.

Well, if you are not willing to learn enough about the topic to speak from an informed perspective... maybe you should be silent. ...

There is nothing more to be said.

 

[Andylusion]

I am finding conflicting information. None seems to come close to your claims.

EU revenue, was only €40 Billion Euros. In which case, you would be right... They have paid about 00.005% of revenue in taxes. That's true. But that's not €40 Billion in profit. That's €40 in Revenue.

According to what I've read, Apple has paid the EU 4% of it's profits in taxes.

Now that's still fairly low, but that is because of how the Irish tax system works. Again the information I've seen is contrary to what you claim. The system Apple has used, is well known, and even has it's own nick-name... the Double Irish Flip. A number of companies take advantage of it.

Indicating it's not a specific aid to a specific company.

Of course there is still some possibility of a hidden arrangement that is exclusive. But even then, that only means that the EU will lose even more revenue. Tim Cook has already said that depending on how this plays out, Apple may pull out of the EU. Not in sales. They will of course keep selling Iphones to whomever they can, but outside of that, they will withdraw their assets and investments in the EU.

Meaning in the short term they'll get the $13 Billion.... Not the EU, but rather Ireland will. But in the long term, billions of Euros will be removed from the EU, and thousands of jobs will be lost, and the tax revenue from those jobs will be lost.

And if Apple pulls out, so will many other companies worried over getting nailed with a heavy tax penalty. The EU could lose hundreds of billions of Euros from this one terrible move. Especially right now, when they need foreign investment and jobs the most.

This is a very bad plan, that if not handled carefully, could have a long term negative impact.

We seem to be reading different newspapers. What you call "the Double Irish Flip" where the Irish government allowed a company registered in Ireland to receive all the profits accrued from states on the European Union (and the rest of the world) but the company was allowed to register another so-called head office in Ireland, with no address or employees. Because two companies exist, it is called the "double Irish" arrangement. It is an illegal scam because the second company is actually a bank account into which Apple was placing 99.995% of its profits tax free. Since the official and perfectly legal corporation tax in Ireland is 12.5%, the Irish government has been facilitating tax avoidance over the years to the tune of €13bn plus interest. By allowing this arrangement, Ireland has been a tax haven. Since other corporations in Ireland are paying 12.5% in tax, the European Commission has found that Ireland has been giving a lower rate of tax to Apple, thereby violating the European Union's fair competition law. If, as you say, other corporations have been getting similar deals from the Irish government, the Irish people would like to know who they are and to have the books examined,

First off.... you seem to be implying that only under Irish law, can a company move profits around from other EU States. As if this was something 'special' about Ireland law.

This is not true. Any company, can create a subsidiary, and move profits either to the subsidiary, or from that subsidiary, and there is absolutely nothing any government can do about. This is universally true, in every country on the planet.

Let us pretend for a moment, that you owned a lemonade company. But you had a subsidiary name Lemonade Plus that actually made the drink, and another subsidiary named Lemonade Retail that sold the drink.

Because you own both the company that makes the Lemonade, and the company which sells the Lemonade, you can move the profits to either company. And there is nothing anyone, or any government can do about it.

If Lemon Plus is in the law tax area, you have it make the Lemonade, and market up the price, and sell it to Lemon Retail at the market. Lemon Retail sells the Lemonade at cost. Lemon Plus records the profits, and Lemon Retail records zero profit.

However, if Lemon Plus is in a high tax area, and Lemon Retail is in the low tax area... you just have Lemon Plus make the lemonade, and sell it at cost. Then Lemon Retail buys the lemonade and marks up the price for sale.

Lemon Plus records zero profit, and Lemon Retail records all the profits.

You can move the profits around at will. You could have the profits switched back and fourth every month, if you wanted to. And there is nothing anyone can do about it.

It's not a "special deal" from Ireland. Unless you do away with freedom, and nationalize everything.... any company can do this, from any country around the entire globe.

They do have some "Transfer Pricing" rules, and Ireland has put in place these rules over the past 10 years. But the fact is, even those rules are not all that effective, because you have to rely on the company to file the estimates of what the transfer pricing should be. Why? Because product moved between subsidiaries isn't on the general market. Thus there is no market to base that price on. You have no choice but to have the company tell you what it should be.

Now it is true that for a long time Ireland had a system where a company could incorporate in Ireland, without being a resident of Ireland.

I will grant you that. And I will also admit that Apple in the 1980s, had that arrangement, where they were incorporated, but not a tax resident, meaning they avoided most of Ireland's corporate taxes, while at the same time, using Ireland to pay low taxes on their profits. Thus, they had a corporation with no address, and no employees.

That however hasn't been true in decades.

View attachment 89092

This is Apple Corporate Headquarters, located in Cork Ireland.
View attachment 89094
This is a real place, with a real address, with real employees. Nearly 5,000 employees work high paying corporate jobs for Apple computer in Ireland.

Real jobs that could be very easily lost. The whole reason Apple invested into Ireland to begin with, was because of the competitive tax rates. If you eliminate the reason for them being there, they could very easily move elsewhere.

And Tim Cook, has already said in no uncertain terms, that if the EU screws this up, they could very well move out of the area.

Lastly, you claimed that other corporations operating in Ireland, are paying 12.5%. This isn't true.

There is no evidence, that Apple has a lower corporate tax rate, or that other corporations have a higher tax rate.

The newspapers you are reading, are ignorant.

The papers are confusing 'effective' tax rates, with the 'stated' tax rate. The stated tax rate is 12.5%. But just like your personal income taxes, the stated rate, and the effective rate, are completely different.

Just like me. I am in a 25% tax bracket. But I have never yet paid 25% of my income in taxes. Why? Deductions. Interest deductions, medical expense deductions, student loan deductions, charitable giving deductions. Three years ago, my income tax was zero. My personal income tax rate, was 0%. I was paid zero.

Does that mean I had some magic special exclusive deal with the United States Federal government? No. It was simply how the tax law is written.

Apple too, has deductions. Ireland, like most countries, has many deductions. For example, all the taxes Apple pays to other countries, are deductible in Ireland. Same is true in the US, by the way. If Apple pays $10 Billion in Europe, and brings the money home, they can deduct $10 Billion from their US tax bill.

Ireland allows deductions for investments in Ireland. Again, another reason Apple invested in Ireland.

And by the way, ALL companies in Ireland benefit from these deductions.

Effective Rates of Corporation Tax in Ireland by Seamus Coffey :: SSRN

This research paper was published by the University of Cork Ireland. Even they found that companies around Ireland rarely paid 12.5% in taxes. The effective tax rate, is much lower, with many companies pay just a few percent of their profits in taxes.

Again... this isn't a special deal with Apple, and no, all other companies are not paying 12.5%. They all pay, more tax, and less tax, depending on the deductions they qualify for.

And this idea that Apple paid only 00.005% in taxes... I doubt it. Ireland itself, said openly they paid 4%. Which is in line with what the research paper from Cork University says.

Again, my argument to you, would be the same as before.

This deal with the EU forcing high taxes on companies, has zero positives, and tons of negatives.

There is no good thing that is going to come from this. You jack up taxes on corporations, and they'll leave. Especially when the only reason they were there to begin with, was for the tax advantages.

What is the win here? More unemployed people? Less investment in your country? Lower growth? Fewer jobs?

What exactly do you think is going to happen as a result of this, that is going to be 'good'?

Forgive me but your gobbledygook is precisely the sort of spiv talk that Apple and its enabler politicians have been saying but they have been caught in their scam of creating a bogus company for the purpose of avoiding tax on profits. Apple is a multi-billion company and their well-remunerated lawyers will lose their case in the European court because everyone knows that their so-called head office does not exist on planet Earth but is holding billions of profits on which no tax was paid. Not only did Ireland facilitate this special deal with Apple while ordinary Irish citizens have been taxed to bail-out the casino bankers and their government has introduced austerity to reimburse speculative bond holders. That the Irish government will now refuse to take the €13bn plus interest which might amount to €19bn and then spend Irish honest taxpayers money to fight this award is both shocking and unethical. Their cheating scheme which allowed Apple to funnel untaxed profits through a nonexistent company registered in Ireland has been found to be against the interests of fair competition and they will lose in court. While Apple can take the hit, Ireland cannot afford to continue as a shameful tax haven whose reputation as an honest place to do business is already in tatters.

Well, if you are not willing to learn enough about the topic to speak from an informed perspective... maybe you should be silent. ...

There is nothing more to be said.

Agreed. Can't answer a single point... claim everything I bring up is "gobbledygook", and then when confronted, respond with "nothing more to be said".

I agree completely. You are finished. Have a nice day.