Ireland: we are not to blame for Apple tax affairs

Ireland: we are 'not to blame' for Apple tax affairs


Ireland refused to take the blame Apple's low global tax payments after a US
Senate report said the company paid little or nothing on billions of dollars of
profits stashed in Irish subsidiaries.








A panel of senior politicians
are set to quiz chief executive Tim Cook and two other senior executives at
Apple on the findings of an investigation by the US Senate on
Tuesday. Photo:
AP






By Denise Roland

1:17PM BST 21 May 2013

21 Comments




The US Senate Committee unleashed heavy criticism on the California-based
company on Monday, branding its complex structure the "Holy Grail
of tax avoidance". According to a Committee report, the structure includes three
Irish-based subsidiaries that appear not to be a tax resident anywhere in the
world.


"They are not issues that arise from the Irish taxation system," deputy prime
minister Eamon Gilmore told national broadcaster RTE on Tuesday when asked about
the report.


"They are issues that arise from the taxation systems in other jurisdictions
and that is an issue that has to be addressed first of all in those
jurisdictions."


A panel of senior politicians are set to quiz chief executive Tim Cook and
two other senior executives at Apple on the findings of an investigation by the
US Senate on Tuesday. The report focuses on three subsidiaries based in Ireland,
which, it claims, have allowed Apple to avoid billions of dollars in US income
tax.


The Senate report alleges that Apple pays no tax on the $30bn income
generated between 2009 and 2012 at one Ireland-based subsidiary, Apple
Operations International (AOI). It says that by incorporating AOI in Ireland but
managing it from the US, Apple has taken advantage of a tax loophole whereby
Ireland only asserts tax jurisdiction on companies managed there and the US
bases tax residency on where a company is incorporated. As such, Apple is not
tax resident in either country.



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It goes on to accuse Apple of paying an effective tax rate of just 0.05pc on
the $74bn income attached to another Irish subsidiary, Apple Sales International
(ASI), and of declaring no tax residency for a third, Apple Operations Europe
(AOE).

"Apple claims to be the largest US corporate taxpayer, but by sheer size and
scale, it is also among America's largest tax avoiders,” said Senator John
McCain, who co-authored the report with Senator Carl Levin.

Apple funnels profits from its overseas sales into ASI and AOE through a deal
struck thirty years ago, in which the Irish subsidiaries share the costs of
research and development activities in the US in exchange for certain
intellectual property licences on the resulting products. The licenses grant the
Irish subsidiaries the right to the profits generated from sales of Apple
products outside the US.

Apple has said in filings with the US Securities and Exchange Commission that
it has $40.4bn in earnings outside the US on which it hasn’t paid US taxes. If
Apple brought that money back to the US, the company would owe $13.8bn,
according to the filings.

Apple has said in filings with the US Securities and Exchange Commission that
it has $40.4bn in earnings outside the US on which it hasn’t paid US taxes. If
Apple brought that money back to the US, the company would owe $13.8bn,
according to the filings."

This was discussed on TV this morning. As Everyone knows Apple has Billions in cash earning interest but doesn't pay dividends because ir claims the money is needed for investment in new products, however the last two iphones were not so well received. An Investment analyst said Ireland is earning a lot of money with these well known Companies like amazon , apple etc , but the US is on the warpath and far more determined to expose these tax dodgers....pity Britain was't so aggressive.