I like that last one on buying iPads and iPhones. In the past Iâve worked a bit with secondary schools on how to upgrade their IT infrastructure. The minute the cunts get a few grand that should be put into a lab of computers they invariably spend it on iPads for themselves. Millions wasted every year by these cunt buying Netflix devices for home.
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You did no such boring kid, the fact is that 80% of Irelandâs Corporation Tax take comes from MNCs. You donât seem to get either than they are also entitled to reliefs as well, which brings down their effective tax rate. Youâve brought up upward only rents a couple of times on this thread, are you a sucker who signed one, and still doesnât seem to get that it was a matter for the courts?
Do the EU know more than the US Treasury or the Irish Revenue who you disagree with the decision?
That 80% statistic is a nonsense argument. Reasons are :
- Apples rate of tax is 0.005%. Irish SMEâs pay 12.5%. They should be paying more than 80%.
- SMEâs have struggled to make a profit so would be paying less tax.
- One of the reasons they donât make a profit is because of the upward only rent. It is just one reason. Another reason is an increase in rates. Another reason is Irish people were being burdened with extra taxes, had less disposable income which also hit SMEâs. Meanwhile the Irish govt were bending over backwards to help MNCâs avoid paying tax while fleecing indigenous companies.
As to the EU knowing more than the Irish Revenue. If Irish revenue charge foreign companies 0.005% and Irish Companies 12.5% then I wouldnât trust them as far as Iâd throw them. Youâre backing Noonan? This the same Noonan that has overseen NAMA, IBRC, Siteserve and redacted. From what I read Apple have to lodge the money to an account until the appeals process is over. This means they are complying with the EU.
The original point you failed miserably to prove is that Ireland didnât gave a tax write off to Apple. You sound like Brian Hayes.
The journal.ie - âThe Government need their heads examinedâ 
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agreed
he said on the news at one yeaterday that taking the money would be akin to âeating seed potatoesâ⌠i found myself subconsciously nodding away in agreement as i drove to Applegreen for my chicken fillet roll
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What you are saying is fine and dandy but wonât butter parsnips. The crew crying foul over the last 24 hours should be elected in to government and mark my words you will see a U turn .
Some would argue that charging MNCâs more than 0.005% tax would butter plenty of parsnips. I know if I was paying 0.005% income tax I would be having fillet steak for breakfast, dinner and tea with buttered parsnips and carrots on the side.
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Fionnan Sheahan laid into Noonan on the Sean OâRourke show this morning - said Noonan has been completely unprepared despite having several months to co-ordinate a response, and has failed to brief other ministers and compared his performance over this to the worst of the Cowen regime.
Basically said he hasnât a clue what heâs doing.
If the usually lapdog-like Fionnan is destroying Noonan over his performance, things are really bad.
Joseph Stiglitz was on the same show directly after Richard Bruton was on and the first thing he said was that everything Bruton had said was âbalderdashâ.
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Fionnan in a power worshipper. The only thing that angers him more than offence given to our local overlords, is offence given to our international overlords. Weâve been embarrassed in front of the yanks.
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A power worshipper or a Power worshipper?
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Michael has a great way about him.
Itâs great how he can explain really complex financial matters in a way that the TFK community can understand
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Spoke to somebody who knows about tax this morning. Said revenue just applied the law - will be annoyed they gave comfort letter but all comfort letter does is say what their interpretation of law is.
Could be wrong on this but what Irish Revenue did complies with Irish law but not with EU law. Think EU law trumps ours which is why they are telling us to collect.
Not if just a letter of comfort saying what law is. Stretch to say that is state aid. Law itself is not State aid. Argument made that letter of comfort was state aid.
SMEs do not pay 12.5%. They are entitled to transfer pricing regimes, deductions and reliefs as well, the effective Irish rate of CT is lower than 12.5% though. We are mid table in Europe in effective rates.
The facts are the facts, Irish SMEs paid just 20% of our CT last year. The increase in Irish tax revenues has been driven by higher Corporation tax take (Most of the additional revenue - some âŹ2.3bn - came from corporation tax, which was 50.2% higher than expected http://www.rte.ie/news/business/2016/0105/757913-exchequer-figures/).
Once again, there is no writeoff, itâs TP and standard reliefs/deductions. You seem to think that Ireland deserves all of this cash as thereâs 6,000 employees here. When someone buys an iPhone from a network, thatâs only the end of a huge value chain. The R&D was completed in the US, a team of well paid product developers pitched an idea and it was green lit. A bunch of PHDs worked out what hardware was needed, they wrote code to make it all work, they designed the physical device and they built the ecosystem in which it would work (iTunes/IOS). Sales teams there went around the world negotiating contracts with networks to carry Apple phones (remember when iPhones were O2 exclusive when they first arrived, a sales team from the US negotiated those kinds of lucrative deals worldwide). Tim Cook was known as a bit of a supply chain wizard, and hence got the top job from Jobs and his supply chain team put in place manufacturing arrangements all over the world with final assembly in China. Apple will pay consultants and have their own marketing team in US which will devise marketing plans - like the use of U2 from 2005 onwards. Some guys in Cork matched customer orders to products and sent them out at the very end. The Irish share of the value of the transaction is tiny. Goods and services are being transferred to Apple Ireland by the rest of the Apple group and the US and Irish tax authorities require them to be made on an arms length price to prevent profits being manipulated. The US, Ireland and Apple have all agreed how those supplies should be priced (under OECD principles) - and the EU has jumped in trying to overturn this for political reasons. The EU is arguing that as part of its monitoring of state aid it should be able to second guess member states analysis of what constitutes value for transfer pricing purposes. Itâs an attempt at a grab on US tax revenues.
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The EU does not agree with you. Apple recorded all profits through Ireland. The EU had no problem with this. Their problem was with how Ireland only charged tax on the Irish portion of that profit meaning Apple paid no tax on the rest. We are part of the EU. Noonan has been telling us for long enough.
The 80% statistic is misleading. Itâs the equivalent of saying a person earning 500k pays more income tax than someone on 40k. No shit they pay more. Thatâs what youâd expect in an equitable tax system. However if you say the 40k earner pays 2,500 times (12.5%/0.005% = 2,500 ) the rate of tax as the 500k earner then even a numerical illiterate would say it wasnât very equitable.
âWe had a tax holiday for the first 10 years in Ireland. We paid no taxes to the Irish government,â one former finance executive, who asked not to be named, said.
If thatâs not a tax write off then I donât know what is.
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To digress slightly, is that the crutch the Dublin tax firms are clinging to in the case of Sect 110 vehicles for the vulture funds?
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Hon Mick!
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He has a great 'oul way about him alright 