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Can somebody explain to me what about that interview benefits Apple? Maybe I'm getting cranky but I'm seeing a lot of Apple executives give interviews that (to me) are not advancing the interests of the company. Why would they apparently relax discipline on press operations so much when Apple's ability to guide the press has historically been such a great strength?

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iPhones, iPads and other Apple products sold in Europe, Africa, the Middle East and India are registered by Apple Sales International, a subsidiary in Ireland. The commission says almost all the profits from this were allocated to a “head office” with no physical location or staff, that is not based in any country, meaning no tax was paid on its income.

 

Under the terms of Apple’s deals with Ireland, Apple Sales International pays registers just €50m of profits in Ireland, meaning corporation tax of less than €10m. The rest – amounting to tens of billions in profits every year – were not taxed.

 

A second company, Apple Operations Europe, the Irish subsidiary that manufactures Apple Macs in Ireland, used a similar structure to allocate profits to a “head office”. The two companies pay Apple Inc – the US company itself – billions in R&D payments a year, but the rest has contributed to Apple’s growing overseas cash pile, now worth $215bn

 

Smells like a big scam. Apple claims that all the value is generated in Ireland. Yeah right!! The US should only intervene if they give us protection money i.e. all the money stashed outside the US.

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iPhones, iPads and other Apple products sold in Europe, Africa, the Middle East and India are registered by Apple Sales International, a subsidiary in Ireland. The commission says almost all the profits from this were allocated to a “head office” with no physical location or staff, that is not based in any country, meaning no tax was paid on its income.

 

Under the terms of Apple’s deals with Ireland, Apple Sales International pays registers just €50m of profits in Ireland, meaning corporation tax of less than €10m. The rest – amounting to tens of billions in profits every year – were not taxed.

 

A second company, Apple Operations Europe, the Irish subsidiary that manufactures Apple Macs in Ireland, used a similar structure to allocate profits to a “head office”. The two companies pay Apple Inc – the US company itself – billions in R&D payments a year, but the rest has contributed to Apple’s growing overseas cash pile, now worth $215bn

 

Smells like a big scam. Apple claims that all the value is generated in Ireland. Yeah right!! The US should only intervene if they give us protection money i.e. all the money stashed outside the US.

 

Commissioner Margrethe Vestager, Danish and in charge of competition policy, is a lady with bone in the nose, taking on big boys who play foul play. I remember buying an Iphone 3S back in '09 or '10, and the phone came by FedEx from Munich, Southern Germany [in less than 24 hours from time of order, by the way], and the invoice came from Ireland by e-mail. As a CPA I must admit that it caught my attention.

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Great decision by EC. Double Irish and other variants are clearly perversions of the tax system.

I would say that ought to be up to the sovereign governments to decide for themselves!

 

Personally I am for unified EU tax system and then EU based distribution of tax monies.

Well, I am for unified EU overall.

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The US Treasury has weighed in in support of Apple.

 

https://www.treasury.gov/connect/blog/Pages/Treasury-Releases-White-Paper-on-European-Commission%E2%80%99s-State-Aid-Investigations-into-Transfer-Pricing-Rulings.aspx

 

I found this argument to be interesting:

 

"There is the possibility that any repayments ordered by the Commission will be considered foreign income taxes that are creditable against U.S. taxes owed by the companies in the United States.  If so, the companies’ U.S. tax liability would be reduced dollar for dollar by these recoveries when their offshore earnings are repatriated or treated as repatriated as part of possible U.S. tax reform.  To the extent that such foreign taxes are imposed on income that should not have been attributable to the relevant Member State, that outcome is deeply troubling, as it would effectively constitute a transfer of revenue to the EU from the U.S. government and its taxpayers."

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This whole thing seems like it would be like a company like Amazon or Apple saying they just realized they've been charging all their customers 20% less than they wanted to for the last 10 years, and expecting everyone to just pay them money.

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This whole thing seems like it would be like a company like Amazon or Apple saying they just realized they've been charging all their customers 20% less than they wanted to for  the last 10 years, and expecting everyone to just pay them money.

 

They could certainly do that if they were willing to back the "request" up with guns and threats of violence and kidnapping the way governments do.

 

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Well I just hope that the $15 billion that Ireland is about to receive teaches them a lesson and encourages them and others to be more careful about this sort of thing going forward.

 

The rest of the EU members certainly hope so.  Don't you dare try to attract business to your country at the expense of the other member nations with confiscatory tax rates.  "If we can't have a thriving economy, no one can!"  Like all socialist they are driven by envy and think it is preferable that everyone be equally poor rather than some have more than others.  I'm sure GB is breathing a sigh of relief right about now.

 

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6,000 people employed by Apple in Ireland.

 

 

Separately, I hate states giving out tax breaks to lure businesses from other states...

 

Do you hate it when building owners offer companies lower rent for office space to draw them away from other buildings in the city?  Other than the fact that the commercial building owner actually owns the building, what is the difference?  Do you think that if one country raises its tax rates all other countries on the planet should be required to follow?  That would lead to ever increasing tax rates without end. 

 

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6,000 people employed by Apple in Ireland.

 

 

Separately, I hate states giving out tax breaks to lure businesses from other states...

 

Do you hate it when building owners offer companies lower rent for office space to draw them away from other buildings in the city?  Other than the fact that the commercial building owner actually owns the building, what is the difference? 

Private ownership is a big difference. If you take that away, then why not let the government pay for everything?  There is a difference between a business engaging in practices they determine worthwhile versus having a populace of an area subsidize the business, regardless of whether they use it. Now they get the subsidy regardless of their quality of service or competitiveness from others. 

 

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having a populace of an area subsidize the business

 

It's not quite that simple, though, is it? Without a competitive tax rate, the company might not even be there in the first place. And once they are there, if it still brings many jobs and pays substantial tax, that can still be a net benefit over the alternative (which is probably that the business isn't there at all, or has a much smaller presence). The populace, as you say, is probably getting more than they're giving. I don't know what's right, but I think it's telling that Ireland isn't asking for that tax to be higher...

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