The Celtic Phoenix - A thread to list the economic miracles of Michael Noonan & Fine Gael

No obligation to use the repaid tax debt for national debt. Nice one.

Commission decision is contradictory though. “Ireland has to collect all this tax but some of it may be owed in other countries so the other countries should then ask ireland for it”. It’s like they didn’t even slightly expect Ireland to follow the decision, or purposely made it so vague that they couldn’t.

Oh, this is potentially going to be embarrassing for the EU :open_mouth:

Kaiser Noonan is … WINNING

Do you like those apples?

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None of SF Yoof would ever work in Apple.

Yes pal, clearly the EU Commission disagrees, hence this discussion. But so do the US Treasury and Irish Revenue. The EU are playing politics. A left leaning commissioner from Denmark has an agenda. The EU decided after the Recession that they were going to take control of tax competency from individual nations, they got told to fuck off by Ireland et al on tax harmonisation so they are taking a stealth route by using state aide rules.

You don’t seem to understand the EU ruling, have you read it? The first issue they have is headline corporate tax rate Ireland is charging. It’s settled EU law that tax deals for a specific company or industry can amount to state aid if they are “selective” and distorts trade -i.e. provides an impermissible advantage by an EU member state to a beneficiary. That’s based on a Belgian case where the the Belgian Government came up with a tax rate for companies that satisfied a list of conditions that was so extreme that pretty much only one (Belgian) company in the world (the intended target of the deal) could ever qualify for the rate. What the EU are arguing would drive cart and horses through that by claiming a rate that is open to all multi nationals that locate to Ireland should also be treated as being selective because it can distort trade. The Commissioner yesterday was disingenuous yesterday in her statements i.e. claiming it’s some unique deal.

Second and a related issue is how Ireland and Apple allocate the value of its business and therefore calculates the costs of IP supplies into Ireland. Everyone but the EU thinks all that value is located outside Ireland - as I explained earlier. The Irish subsidiary owns little or no IP or assets and all of that licensed to them from the US and Cayman’s on a basis which means the Irish sub pay what the US and Ireland think is an arms length price. This is the reality of value creation and is consistent with OECD rules but it has the effect of reducing taxable profits in Ireland. Effectively, the EU are saying that fuck all of the assets used by Apple Ireland resides outside Ireland and there should be very limited transfer pricing charges. This is ridiculous and goes against everything the OECD has been trying to do with transfer pricing. This is a cash grab on US money by the EU, who are jealous that they are being pummelled by the US in innovation. If this holds, the EU will claim the right to tax most of the sale income from their EU operations as if it were almost all profit. Billions of dollars of costs incurred in the US to develop, maintain and market this tech will be ignored. That is why the US Treasury disagree with this - they want that cake sitting in Bermuda.

But you go on whinging about NAMA, Siteserv et cetera, throw enough shit and it will stick. Ireland and other EU Nations will challenge this in the courts.

The EU is left leaning now? :smiley:

People starving on the street and Sinn FĂŠin are wasting apples :rage:

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Erica would love an apple for her and her little girl.
(As long as it’s a pink lady, with no blemishes, and just the right amount of sweetness)

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Where’s my free apples?

They’re not free apples you pay according to your means. That’ll be €17 please.

I’m not going to argue much more with someone so arrogant they think they know more than the EU. They have lodged the money. If Ireland don’t appeal,the money is theirs. We’re a laughing stock.
Your original point on Ireland not giving tax write offs has been called for the bullshit it was. Leprechaun economist that you are.

The case is getting appealed either way. So obviously Ireland is not going to start spending the money before it has come to a definitive conclusion.

Free apples are a human right

Wasn’t there a cabinet meeting today to decide if we are going to appeal this? I know it would most likely be a foregone conclusion, but it would be interesting to see what the Endapendants do.

Even if we decide not to appeal, Apple can appeal it, right? So either way it gets appealed.

We’ve a great relationship with Apple stretching back 30 odd years… The Nazi party will not break up that relationship. We should take the money and spend it on iTunes.

Some chump last week said Apple couldn’t appeal because no finding has been made against them . That it was Ireland Inc that was being investigated by the EU not apple.

Yes but now a ruling has been made Apple can appeal decision.

Sounds like a chump to me.

Did you ever appeal an apple?