Yep.
Did this for two reasons
They have also repaid a shit load of NAMA debt that was costing virtually nothing and not due til 2020 or something. Free float. And gave it away.
Flatty is talking about something else entirely
Perhaps. Itās a fucking scandal anyways
Lady Thatcher was right, the left wing extremists would rather the poor were poorer so long as the rich were less rich
Iām not talking about Apple. Iām talking about the vulture fund-charity swindle.
They wonāt as the US, where this money money should ultimately be taxed, still have a call on this money.
Double tax hell.
Only tuned into the end of the thread and only spotted that after Iād replied. Oops.
Itās ok. No one understood you anyway.
Sure at least I didnāt accuse anyone of having crabs
It isnāt a strong argument at all. Ireland hasnāt a leg to stand on and govt need to play their cards carefully here or the EU will nail their asses to the wall. Taxes are paid on profit not revenue. The legal argument that Apple can declare their profit in Ireland on EU sales is that the IP associated with the products resides in Ireland (it does, legally). The Irish govt run the risk of total ridicule if they go down the road of arguing the profit belongs elsewhere, when they facilitated it being declared in Ireland.
The EU will win this case, although it will take time.
Ireland only taxes resident companies.
Apple Sales International is resident in Ireland. If they were resident in the US they would be paying tax in the US and they are not. The whole fucking point here is that there is no tax being paid anywhere on tens of billions of profit per year. Even Apple are not denying that.
Until 2014 Irish tax law allowed for stateless entities. Didnāt have to be resident in Ireland or indeed any country. That is structure Apple used. When law changed they changed structure and more tax was paid.
It was all legally compliant with law as it existed.
In one sense itās the point, but in another, more legal sense, itās irrelevant.
Apple will argue that there was no deal with the Irish Revenue which was unique to them, and that other companies had the same opportunity to do what they did.
ā¦and the EU ruling (covering the years 2003 - 2014) is that the tax law allowing for stateless entities was illegal under EU law, as it conferred competitive advantage to one corporation over others. If Ireland didnāt like EU law, they shouldnāt have signed the Lisbon agreement. The point that is being missed here by everyone is that this is an anti-trust case, and neither Apple nor Ireland have a leg to stand on.
European companies had no such opportunity, as the countries they are based in would ensure they paid their taxes (unlike the US which has turned a blind eye to tax avoidance strategies for decades). The whole point of this anti-trust litigation is that Ireland provided US MNCs with a competitive advantage by effectively eliminating their tax burden on sales in Europe. Tim Cook can squeal all he likes to the Irish Independent, they are going to lose.
That is nub of it. A huge stretch to get there as typically state aid requires some element of discretion. Tax exemptions are state aid but no exemption here just law being applied. Needs to be selective to be state aid.
a political decision as it is using state aid rules to attack a domestic tax regime that is outside its jurisdiction. I expect it will be appealed successfully on that basis - domestic tax law is outside EU competence and all that was done was apply the law without any discretion.
Who knew we had so many tax experts and economists on the board.
That American cunt Labane wants our money and our industry. Cant we just send him Glas instead?