Slashdot Mirror
Apple Files 14-Point Appeal Against European Commission's $14 Billion Tax Edict (appleinsider.com)
An anonymous reader shares an AppleInsider report: Apple has filed its appeal with the European court of appeals, all declaring that the European Commission's decision to levy $14 billion in taxes on Apple on behalf of the EU is erroneous, against the rule of law, and should be stricken. The 14 points of appeal introduced by Apple on Monday challenge the European Commission (EC) on several fronts. Primarily, Apple contests that the Cork, Ireland, headquarters of Apple's European wing was properly set up, in accordance with all regulations and laws. Additionally, other apparent accounting blunders by the EC while making its decision were brought up as well. Apple points out that the taxable income attributed to the Ireland branch was misapplied, giving more weight to the Irish operation than it should, and that back taxes were being applied to worldwide profits.
Well, Apple.
The EU is applying the back taxes to worldwide profits, as Apple is choosing to transfer those profits
to the EU using IP licensing charges, and therefore those profits ARE present in the EU.
That, kids, is why they play this game. They hide worldwide profits in a tax haven, but now they want to
pretend they didnt do that.. Boo Hoo.
And then they won't be able to move their taxable profit from EU countries to Ireland. I doubt the EU splitting up will be beneficial to Apple's tax position.
1. Apple pays the taxes and admits no wrongdoing, quietly sweeping this incident under the rug and hoping to never have to endure it again by greasing more than just irish hands
2. Ireland admits it illegally undertaxed apple and skirted EU tax laws, thus opening up cause for additional investigation of facebook, google, and other megacorps that conveniently headquartered in Ireland because of, er, the weather.
Good people go to bed earlier.
maybe they would not have been if Apple had not been using the Ireland operation to funnel worldwide profits there to dodge local taxes worldwide.......
look if apple had wanted to pay the taxes locally it could have, but instead it chose to funnel them there,
world was created 5 seconds before this post as it is.
3. Apple pays Ireland seven billion dollars to leave the E.U.
Or you can think of any variant you like of "what can Apple do with up to fourteen billion Euros that would cause the E.U. to back off".
As the old saying goes: Billions for defense, but not one cent for tribute!
"There is more worth loving than we have strength to love." - Brian Jay Stanley
Already! Any normal American would be in PRISON for 10,000 years by now!
Well, Apple is losing ground on China, I'm pretty sure they don't want to lose a market as big as Europe... just saying.
Your mistake is in assuming Apple isn't abiding by all the local laws. They did, but the EU thought they could change the laws and apply taxes retroactively.
Generically this category of taxation is called either communism or fraud.
Actually, it's millions,
No - in the story in question, it is billions... You may want to familiarize yourself with the concept of paraphrasing.
It's makes you writing much more interesting and relevant when using old quotes.
"There is more worth loving than we have strength to love." - Brian Jay Stanley
Ireland was part of an agreement that set minimum corporate taxes. They ignored the agreement, therefore Apple owes money.
If you got a letter saying you owed a buck and a quarter in taxes
Apple's cash after you remove current debt is roughly $200 billion (conservative estimate as they have over $50 billion in debts).
!4 billion in Euros is roughly $14,814,100,000 billion US, or almost fifteen billion...
That means that what the E.U. is asking for is 7.5% of Apple's cash. I don't know how much you make but I assure you that in my case 7.5% of my house and savings comes to quite a lot more than $1.25, and in fact I would be taking that up with the tax court if I felt they were wrong.
Regardless, you're on Slashdot shilling for your favorite consumer electronics company.
It's a new definition of shilling to claim that fighting injustices is equal to promoting a company. I'm not promoting Apple - I'm saying what the E.U. is doing is theft, and would say the same thing about any company the E.U. s trying to illegally steal money from.
Look, they know they're tax cheats.
You "know" that, but then you know so many things that are not so...
Let it go, man. Let it go.
That is what I'm advising the E.U. to do. And you; why do you care about what the E.U. and Apple are doing in Europe? I am interested because I have a small financial interest, I own some Apple stock (big surprise). But what is YOUR deal that you care so much to post so fervently on the topic? That is super creepy man.
P.S. by your own argument you cannot care that I own Apple stock, because the amount you claim is so little it would have no effect on Apple cash and therefore share price to give it up, right? Ha! We'll see your tune change soon enough I'm sure.
"There is more worth loving than we have strength to love." - Brian Jay Stanley
...and we will let you off all profit on which tax has been paid. All profit that has not had tax paid on it is due.
I love stacking my barbecues in the shed at the end of summer - you can't beat a bit of grill on grill action.
You are mistakenly assuming "tax dodge" means "illegal tax evasion". When it more likely means "improper tax avoidance".
Care to try again?
Learn to love Alaska
Basically apple being a crook. Nothing new.
Should Apple just hand over $14B or spend $20M on a strategy with a 10% chance of paying $0?
How much an Apple is like a Big Mac.
My ism, it's full of beliefs.
Then why do US citizens have to pay taxes to the USA no matter where in the world you live? Hypocrite much?
"Freedom in the USA is not the ability to do what you want. It is the ability to stop others from doing what THEY want"
They must think the E.U. is having trouble seeing things their way.
If this doesn't work they'll use 24 points to make a bigger impact.
This issue is very simple to solve with a few changes to tax policy.
1. Remove deductions for Intellectual Property payments. This is the chief way corporations avoid tax. Example, Burger King / Tim Horton merger.
2. Profit, no matter where situated, is taxable in the country of origin. Example: If Apple sells 100 billion in the US, then the gross profit of that 100 billion is due in the US. Self dealing exchange of expenses by off shoring 99.9% of the price of the phone (or other product/service) would no longer be allowed.
These steps will never be taken because they would be incredibly disruptive in the first place, and in the second place, there is no will in Washington to make corporations or billionaires actually pay taxes as the average person does.
Necessity is the plea for every infringement of human freedom. It is the argument of tyrants; it is the creed of slaves.
Of course Apple transfers profits. They do this by one company division charging another division a fictional/unrealistic licensing fee, causing the worldwide retail branches to see higher costs and be less profitable, whilst the Irish licensing branch becomes more profitable.
The fact that the Irish branch barely employs any people and is largely just a convenient IP holder makes this even more blatant.
See https://en.wikipedia.org/wiki/...
Know for a fact a very large company,nearly Apple size, uses the same method through another EU country.Friend did their tax returns for years.
They are trying to enforce the agreement that companies have to be taxed equally. This agreement has a very good reason for existing - so countries can't give special tax breaks to companies based in that country while heavily taxing all foreign competition.
Ireland is part of this agreement. So they aren't allowed to give Apple a special deal.
That's why it is called 'getting high'.
My ism, it's full of beliefs.
Apple was abiding with a special deal Ireland made with them but the deal was illegal according to EU regulations. What the EU did is basically tell Ireland "you cannot treat Apple favourably compared to other companies since it would be unfair to the companies not getting the special deal, so your special deal is null and void and your own regular taxation applies instead".
Unfortunately, this story is about much more than just Apple and/or Ireland.
The tax practices employed by Apple (and others, including Microsoft, Amazon, Facebook, Starbucks and others - and I don't mean to pick on US companies, but by and large they do appear to be the most flagrant abusers of this system) use tax "vehicles" such as the licensing of intellectual property rights to move exceptionally large amounts of cash from one country [tax jurisdiction] to another, thereby massively reducing their tax burden.
However, for the "donor" country - i.e. the one that is not collecting any tax revenues from the sales achieved by that company, the problem gets much, much worse. The literally billions in taxes not being paid to these countries still has to be collected from somewhere. And that is exactly what happens - the individual, personal tax payers of those nations end up footing the bill.
Next, it gets worse still...
The governments of countries with "higher" Corporation Tax regimes then get visits from senior management from these large multinationals, explaining that of course they would like to "do more business" [and thus pay more tax] in those nations. Except, of course, the tax levels are just, simply, too painfully high. So, regrettably, the company will move its regional offices next door, to a lower tax regime.
The net result of all this is that countries the world over appear to be in a "race to the bottom" because they are told that this is the only way to attract inward investment. This is simply not true.
If we take a country such as the UK, for example [currently embarking on an acrimonious but necessary divorce from the EU... and look at the tax-paying population and the amount of tax involved... the literally billions in revenue that is transferred off-shore to avoid the payment of UK Corporation tax would, if actually paid in the UK, cut taxes for UK citizens by a staggering amount. The basic rate of personal Income Tax could easily fall from the current 23% to 15% [still more than Corporation Tax in the UK - and never mind the fact that companies get to deduct their expenses first...]
A population granted this extra income would:-
1. Spend more - thus helping to keep the economy moving
2. Save more - thus helping to reduce the burden on the state for things like pensions
3. Invest more - thus helping UK business to grow and prosper
There are countless studies showing that a better standard of living leads to a healthier population. In fact, there are no good reasons for allowing companies to "dodge" paying taxes in the way that is currently allowed [unless, of course, you happen to be a senior manager or shareholder in that company, in which case you stand to reap obscene profits].
The fact that we're even having this discussion should tell you just how corrupt and perverted the system of international taxation has become. The sad part is, that 99% of us are losers in this game...
It's not just citizens, but also anyone with a permanent residence permit (Green Card).
The US is one of two countries that does that, the other one is some third world country that most people will struggle to name or find on a map.
And why? I believe it has to do with the US civil war. It's long over, of course, but the laws stuck around.
Since that's what the EU has ruled it's not really a mistake unless an appeal rules otherwise. Other businesses in Cork were paying the taxes just not Apple.
Not what happened. It was a simple as Apple bullying a local council into letting them avoid taxes or they would move and take all those jobs with them. I've got no idea why you are pretending otherwise, I thought Apple fanboys hated the Pepsi guy who replaced Steve Jobs. The tax evasion was implemented back then.
In this case the EU thinks it was illegal tax evasion hence the massive fine.
Unless an appeal changes it that's a perfectly valid label to put on Apple's actions
They transfer Asia, Oceanic etc profits to the EU.
As an example, despite a lot of sales Apple Australia has made a loss for many years because they buy everything from Apple Ireland and sell below cost. It is called transfer pricing.
To my understanding this is not about US profits. The 14 billion comes from Apple applying what's known as the double Irish tax loophole that used to exist in Irish law, allowing them to effectively dodge paying taxes to either the EU or the US. Quoting the wiki:
The loophole was closed last year:
So Apple (and other large tech companies) have been using both the double irish as well as its other variant the Dutch Sandwhich which functions similarly, to dodge taxes on both sides of the Atlantic, while claiming to European tax-authorities that they're paying tax to the US, and to the US that they're being taxed in Europe, while in reality the majority of the income is not taxed in either. The EC is arguing that the use of these loopholes goes against EU regulations and that they now want these companies to pay what they actually should have been paying all the time. This is going to drag in courts for a long time, and Apple is going to claim that since it functioned within Irish law (at the time) it shouldn't have to pay anything. The EC on the other hand, is going to build their case on the grounds that the Irish law itself that allowed for this arrangement was in breach of EU law and cannot be followed and back-taxes are owned.
This whole case is one of several ongoing ones regarding the use of tax-havens to dodge corporate taxes, which has been (and still is in some senses) relatively easy to do for large multinationals. The EU is currently trying to crack down on it, whereas the US, especially now under Trump's heavily wall street backed cabinet, is g
"It is the business of the future to be dangerous" -Alfred North Whitehead
BULLSHIT. You are seriously going to try and tell us that apple doesn't license its IP cheaply to international subs in low tax zones? or that none of its sub charge them high fees for services or goods from other countries? transferring profits isn't just about sending the profits from your local sales offshore, it is also about realising profits and losses in different countries by transferring costs through pricing. This isn't just some tactic Apple uses either, but if you seriously think Apple don't do it then you are delusional.
If demanding taxes to be paid is "stealing", then what do you call it when somebody uses resources they aren't paying for? You know, if a person feels entitled to exploit the generosity of others and gives nothing back, we call him a parasite and suspect him of being a psychopath, so what kind of person is Apple? And if Ireland gives unreasonable tax benefits to certain, big corporations, does that not skew the market that is the very foundation of the EU (and which, incidentally, is the reason why Ireland wants to be a member)?
I have a good deal of respect for people who honestly believe in freedom and free market capitalism (even if I don't agree), but what you are talking about is just nonsense. The free market only stays free in any meaningful sense, if everybody genuinely agrees to follow the same rules, and that includes taxation and competition.
We don't have rednecks, that's an American Innovation (tm).
Yeah, in Britain they are called wetnecks.
Of course news about a fake are Fake News.
The fact that the Irish branch barely employs any people and is largely just a convenient IP holder makes this even more blatant.
Apple Ireland employs around 4,000 people in Cork, in areas from sales to finance to customer support. It's a major employer in the city and has been for over 30 years, where it used to provide a lot of manufacturing jobs (few of these are left now). The only country in the EU with more Apple employees is the UK, where the number of Apple retail stores (37) explains the difference.
So it's hardly a brass-plate operation.
Rational thought is the only true freedom
The double Irish tax maneuver is worthless on its own without the Dutch sandwich.
The double Irish involves having an Irish registered company legally headquartered elsewhere than the EU (like the Caymans) as well as an Irish registered company headquartered in the EU. This used to be allowed, but it is not allowed any more (and existing structures of this sort have to wind down over the next few years).
There are two components to this. First, the Irish tax is based on where the income is made and only tax Irish income, so do not tax based on income from sales outside the country. This seems reasonable on it's own, but it interacts with other countries tax rules which tax based on where the income is booked. As a result, a company can book profits in Ireland, and fall into the gap between these positions.
The second component is profit moving - the resultant profits can be moved between the resident company and the non-resident company at no (or extremely low) taxes, but moving the money out of the EU to the external HQ would be taxed heavily from Ireland. However, this is not taxed heavily in Holland (due to historical attachments to the Dutch Antilles). So the organization move the money to Holland (inter-EU transfer, low tax), and from that subsidiary to the tax haven (Dutch law, low tax) and then have it in a tax haven for a very low cost. Where they sit on it because the US tax is punishing.
The solution is not higher taxes, it's closing these gaps that companies exploit.
Rational thought is the only true freedom
Actually, that's not correct. They're enforcing an agreement that all companies inside a jurisdiction have to be treated the same. If Ireland wanted 0% corporate tax, and applied that to everyone that would be inside the rules. What the Commission decided is that the deal Apple got was an unfair subsidy because no-one else used it. Ireland and Apple say that it was available to everyone, so it wasn't a subsidy and it wasn't unfair.
Rational thought is the only true freedom
Thank you for the accurate clarification, this is indeed so and I should have explained it in more detail but I was running out of time and had to post an insufficient explanation of the scheme.
You are indeed correct. This case (and other like it) revolve around whether or not the companies can be taxed for using those loopholes (which are now either closed or being closed) in the past. In other words what's being debated is whether or not the national Dutch/Irish laws that have been exploited for this effect were in line with EU laws and agreements,
"It is the business of the future to be dangerous" -Alfred North Whitehead
We don't have rednecks, that's an American Innovation (tm).
Yeah, in Britain they are called wetnecks.
No, they are called scallys
Wanna buy a shirt?
https://www.redbubble.com/people/stealthfinger/shop?asc=u
The solution is not higher taxes, it's closing these gaps that companies exploit.
Doesn't this just end up boiling down to higher effective taxes?
You total up your revenue or profits and divide by what you actually paid in taxes and that's your effective tax rate? I don't think at the scale and complexity of a corporation the size of Apple the notion of a nominal tax rate makes much sense.
So if you close loopholes to increase the absolute amount of tax paid, you're raising the effective tax rate even if the nominal one stays the same. In fact I'd be surprised that its not a rhetorical argument used in lobbying and negotiation -- don't raise our tax rate, close loophole X and we'll pay a higher effective rate (meanwhile, their tax wonks have figured out how to use loophole Y instead).
My general sense is that the larger problem isn't paying or not paying taxes, its the cash hoarding these semi-monopoly companies do. A lot of the money just ends up in short-term treasuries or other semi-liquid investment vehicles and doesn't circulate in the economy. In some ways, taxes can be seen as the economic investment of last resort -- a way to bring hoarded capital into the market.
A better policy would seem to be incentives to spend and not hoard capital so it gets put into motion in the economy.
The EU doesn't want those taxes, they want Ireland to collect them according to their tax schedule in order to create a level playing field in the EU. What local business wouldn't love a 0.005% effective corporate tax rate? Most pay 20-25%
If construction was anything like programming, an incorrectly fitted lock would bring down the entire building...
Doesn't this just end up boiling down to higher effective taxes?
For companies the size and structure of Apple, yes it does, although then they'd move on to more aggressive transfer pricing or something else.
My general sense is that the larger problem isn't paying or not paying taxes, its the cash hoarding these semi-monopoly companies do. A lot of the money just ends up in short-term treasuries or other semi-liquid investment vehicles and doesn't circulate in the economy. In some ways, taxes can be seen as the economic investment of last resort -- a way to bring hoarded capital into the market.
Yes, I tend to agree with this, although the not-paying of taxes is a contributory factor in the cash hoarding .The cash hoards get so large in part because of the tax avoidance. A further factor is the US corporation tax rules, and rates, which are very high.
A better policy would seem to be incentives to spend and not hoard capital so it gets put into motion in the economy.
Easier said than done! Although companies have figured out some ways around this, Apple again being one of the innovators. If they need liquidity in the States that they don't have (because their dragon's hoard is in Barbados) they simply borrow. The cash hoard is collateral, and the interest rates are very, very low because Apple are not a default risk with 200 billion dollars lying about behind the couch. So they have liquidity where they need it without giving up 35% of their money. Apple don't care about their 200 billion being offshore and (technically) inaccessible because there is nothing they want or need to do with it that they can't do out of normal revenue (which they'll probably get a tax break for) or cheap loans.
On a more general point, a further problem is that at the moment, business capital is not in short supply due to the very low interest rates so there's capital looking for opportunities. Historically we can say this is a dangerous situation as this situation can lead to a tendency to inflate stocks which can lead to a bubble/burst situation. Taxes could soak up some of this excess capital and allow it to be spent on the collective in the form of public infrastructure but at the moment it is difficult to tax and business largely have no reason to invest in public infrastructure. So the money is static (as in it is not circulating) and at a time when the US is richer than at any time in its history it has infrastructure problems and those who could be employed in fixing it are idle.
Rational thought is the only true freedom
Sure. Tell us how important Ireland is for Apple products worldwide. It will still sound stupid, but go for it.
Ah I forgot - the BBC and all the rest other than Breitbart are "fake news" now.
Just ignore the chatter of the adults we don't matter.
We don't have rednecks, that's an American Innovation (tm).
Yeah, in Britain they are called wetnecks.
No, they are called scallys
I thought they were Scousers.
Calling someone a "hater" only means you can not rationally rebut their argument.
"Apple also points out that drawing comparisons to other tax arrangements in the EU with other multi-national companies is improper, as the facts and laws differ from agreement to agreement. As such, Apple argues that their use in a legal battle about taxes is inappropriate and unfairly prejudicial to Apple."
That's the point of doing business with the EU Apple, uniformity. If you don't like it then maybe you should have backed Britain in their Brexit vote and not spread FUD.
You accounting shenanigans are coming home to roost. Pay your taxes hippie.
The EU doesn't want those taxes, they want Ireland to collect them according to their tax schedule in order to create a level playing field in the EU. What local business wouldn't love a 0.005% effective corporate tax rate? Most pay 20-25%
The EU wants Ireland to stop being a money drain.
Brussels is simply forcing the Irish govt to do what they don't want to do, given that Ireland took the EU's money the EU has some entitlement to do this (which is why the EU cant dictate terms to the UK... well at least until we lose the ability to veto things after brexit).
Calling someone a "hater" only means you can not rationally rebut their argument.
And the argument from Apple (and Ireland) is that they are not being treated differently, that the EU hasn't provided a valid legal argument that they are, and is flat out wrong on matters both of law and fact.
How is this relevant to either the great-grandparent post (claiming that Apple Ireland was barely a fig leaf because there were so few workers) and my original post (which pointed out that 4,000 people isn't a brass-plate operation)?
Ireland, as it turns out, is important to Apple or they wouldn't base so many people there for so long. Similarly, Google, IBM, Facebook, Intel, Cisco, HP, Eriksson, Analog, Dell/EMV, Microsoft - all the biggest European and American technology firms have substantial operations in Ireland in Dublin, Cork, Limerick, Galway, Leixlip and Athlone. Up until a few years ago they absolutely could have been two guys and a dog, and it wasn't on anyone's hitlist. But all of them employ thousands of people in development, manufacturing, sales, customer support and finance. Hell, Dell moved it's entire 5,000 person EU manufacturing hub out of Ireland and still employs over a thousand people before they bought EMC (which added thousands more).
So it's more than taxes, although that's part of an overall attractive package that includes close cultural ties with America, native English speaking with strong second language skills, and good education.
Rational thought is the only true freedom
The EU is applying the back taxes to worldwide profits, as Apple is choosing to transfer those profits to the EU
Apple doesn't transfer U.S. profits to to the EU, so how is it fair for the E.U. to tax Apple on U.S. profits again exactly?
That, kids, is why they play this game.
There are $14 billion reasons why the EU is playing this game but legality or fairness is not one of them.
Ireland does not charge taxes for profit made in other countries. Apple transferred their profits to Ireland to avoid paying taxes in other countries. If they transferred US profits to Ireland then, yes, they do have to pay tax on it. This is because of the way that Apple transfers the money - as a patent licensing fee. The subsidiary in Ireland is making a profit on all those fees they paid to Ireland worldwide.
At the time, there were no other companies. This goes all the way back to 1976 when Ireland had bugger all industry of any kind. To attract investment Ireland offered generous tax levels, generous tax rebates and write-offs, particularly in the area of R&D. Other companies use and have used similar programmes of course (Dell, for instance, took 10 years of generous tax rates and when the deal expired promptly moved all the manufacturing off to Poland or Hungary). It's just that Apple having been here longer, got a larger benefit.
This continues until today, and indeed is used by all countries (we currently incentivize R&D work at >100% tax write off so the more research you do here, the less tax you have to pay).
Rational thought is the only true freedom
Well, Apple is losing ground on China, I'm pretty sure they don't want to lose a market as big as Europe... just saying.
You apparently haven't been paying attention.
At the rate that Apple is "losing ground", your hypothetical grandchildren will still be buying Apple stock at over $100 a share.
Same thing for the most part.
Wanna buy a shirt?
https://www.redbubble.com/people/stealthfinger/shop?asc=u
That isn't even close to a parallel. Nice try though. Actually it wasn't even a nice try.
I seem to be missing your point, I think. For this case it's irrelevant how "important" Ireland is to Apple (a distinction I'm not sure I understand what you mean by) - what matters is whether the tax regime used by Apple (strictly speaking, the corporate structure that Apple used to move money about) was available to everyone or not. Ireland say it was, the EU say nu-uh.
The EU countries are allowed to compete on tax, and indeed Luxembourg is well known for this. All countries incentivize particular industries in various ways which incentivizes behaviour. Holland levies particularly low taxes on transfers to outside the EU, which Ireland doesn't. Ireland only taxes corporate profits earned inside Ireland, whereas France and Germany only tax corporate profits booked inside their borders. France has a corporation tax rate of 35% that no one actually pays - the rate that was until recently advertised on their industrial development agency's website was somewhere around 6% due to various incentives. The UK is generous around bonuses, whereas all income in Ireland is taxable (if you get a company car, you pay income tax on the value of it - we don't get company cars here).
The thing is that morally, sure, the structure stinks. But legally the EU's case is very, very shaky. For one thing, the .0002 tax rate assumes all global income would be taxed, which is just not true under Irish tax law. For another, Apple requested advice and received clearance from the Irish Revenue Commissioners about this. So it will go to court, and no-one except the lawyers will win, as always.
That said, forget about the common corporate tax base (which is what this appears to be about behind the scenes) but the EU countries should agree a common approach to assess what income is taxable. This would close most of the loopholes that the money is pouring through at the moment, and would appear to be easier to agree on than, say, an EU-wide minimum corporate tax.
Rational thought is the only true freedom
Ah I forgot - the BBC and all the rest other than Breitbart are "fake news" now. Just ignore the chatter of the adults we don't matter.
Oooh, an "adult". Well, that still wouldn't prove you are not a moron, even adults can be. Your posting proves you are a moron. Your reply proves you are also delusional. By, you moron, wo believes this whole tax thing is about "Apple bullying a local council into letting them avoid taxes".
Of course news about a fake are Fake News.
And none of those 4000 people are involved in generating intellectual property - for which the Irish company collects the tax-free royalties. Nobody said Apple doesn't have a real office in Ireland - just that that office is being credited for revenues it didn't really produce. That's the game.
Posted from my Android phone. Oh, I can change this? There, that's better...
Its more like 100 Billion in debt.
Yes I know that (with long term factored in) but I was trying to present the worst possible number or my argument....
If you factor in your debt estimate to my original numbers, then the percentage the EU is asking for is more like 14%, not 7.5%, making the EU's request even more absurd and unreasonable...
I think you for the support but really like I said, I prefer to show that even the worst case is still too high a percentage, rather than showing a more accurate number that is more open to debate.
"There is more worth loving than we have strength to love." - Brian Jay Stanley
And none of those 4000 people are involved in generating intellectual property
If you look on Apple's jobs website, there are technical jobs in Cork - including software engineering.
"There is more worth loving than we have strength to love." - Brian Jay Stanley
Apple was abiding with a special deal Ireland made with them but the deal was illegal according to EU regulations. What the EU did is basically tell Ireland "you cannot treat Apple favourably compared to other companies since it would be unfair to the companies not getting the special deal, so your special deal is null and void and your own regular taxation applies instead".
My distrust in others makes me want to think that Ireland (or factions in it anyway) knew or hoped this would happen all along figuring if they can lure Apple into bringing in all their money and then let the EU be the bad guy and make Apple give Ireland the money.
Then maybe blame the company for moving their taxable profit to a tax-haven EU Country? Apple made a dick move and got caught, we need to modify our laws so that dick moves like those are completely unrewarding. The border tax or some equivalent VAT would work.
Only I can judge you.
Facts. The natural enemy of apple fanbois everywhere.
It's how it happened, a good description of the government of County Cork and is why the penalty is so huge.
So kid, tell me the "spun" version. The EU hates Apple's freedoms?
beating amazon is hardly amazing, Amazon have paid less than a lot of small businesses given they run at a loss. try comparing them to real companies that aren't writing off massive growth to ensure they pay no tax. Apple does cost transfers for parts and goods purchased from their subs. They also license the low cost subs like Ireland at cheap rates so that the the real profits are not accrued in the US.
Unfortunately, that "extra bit of paperwork" can prove to be somewhere between "quite a bit" and "impossible to do it correctly without expensive professional help".
First, it is not easy to find professional help with US taxes outside the US. The people who provide such services usually do so for corporations and affluent individuals and price their services accordingly. In the real of middle class wages, that means you're going to pay a significant part of your income if you need such help.
Second, the taxation treaties that are meant to prevent double taxation are worded in a way that makes them hard (up to impossible) to understand for someone without legal training.
Third, taxation can have quite a few quirks, for example how securities and their earnings are taxed (I believe the US taxes 'virtual' profits, while other countries may tax realized profits - and the financial institutions there only provide a report of those. Good luck figuring out the figures you need to report to the IRS.)
If you're a US citizen living abroad, make $15k (fifteen k) per year *and* have to file US taxes, you have two choices - do the paperwork yourself (no chance to get it right) and hope for the best, or pay a significant chunk of your meagre income to a professional, if you can find one.
Then move to a nice tax free area of the world and mail the IRS a photocopy of your middle finger every april? Sounds fair.
That's pretty much how the world does it (except for the "mail something to the tax authorities" part - if you're not a resident, you don't have to mail anything to the tax authorities, because you're not liable to pay any taxes), with the exception of two countries, one of them being some third-world place that most people won't find on a map.
It's how it happened, a good description of the government of County Cork and is why the penalty is so huge. So kid, tell me the "spun" version. The EU hates Apple's freedoms?
Say, in you reality, are there Zeppelins in the sky?
Of course news about a fake are Fake News.
We don't have rednecks
Listening to interviews of "informed" British citizens during brexit, I beg to differ.
My distrust in others makes me want to think that Ireland (or factions in it anyway) knew or hoped this would happen all along figuring if they can lure Apple into bringing in all their money and then let the EU be the bad guy and make Apple give Ireland the money.
Common sense would lead me to believe that Apple knew exactly what risks it was taking, and had much, MUCH better legal advice than did Ireland.
Not following why. Obviously they didn't talk to the correct authorities. So they will get bit.
Laws are rules for the court, but merely a bottom bar to hit for life. Think beyond laws in your actions always.
Yes a cool joke for your bros but utterly useless. How about we return to reality then since you are making a fuss about me apparently denying it?
So then - what really happened between John Sculley and County Cork? There's no point just telling me I'm wrong without any indication of why. Something more than "Apple can do no wrong" is required.
Gee, why doNn't you finally point to the BBC report on it? Or from any other non-fake news source but the Daily Moron? That should be interesting.
Of course news about a fake are Fake News.
So you've got nothing apart from "Zeppelins in the sky" to counter the news about that's in the summary FFS?
Pathetic.
Fanboy cheering of "Apple can do no wrong" with zero content.
The Irish Tax authority isn't the right authority on what taxes are owed in Ireland? What crack are you on, and where can I get some?
APK likes to ask for responses to the same things over and over. Maybe he just likes the responses?
If they were, then the EU wouldn't be able to cite specific laws that were in place at the time and not followed. If you go to a store and the man behind the counter tells you it's ok to pay $0.05 for a drink and a chocolate bar, do you believe the person behind the counter or do you ask more questions?
Laws are rules for the court, but merely a bottom bar to hit for life. Think beyond laws in your actions always.
What? You're filing a joint return so you don't have to pay as much taxes? YOU TAX DODGER! Apple took advantage of a legal loophole they didn't make the loophole: Ireland did. Now the EU says it's illegal that's not Apple's bad.