Iām just pointing out a fact.
Apple have now paid a higher rate of tax in the US than they would have in Ireland, as I said consistently would happen.
The EU are going to court now to argue fundamental OECD principles. The US Government will soon be an appelant in the case as they donāt want to lose money that is rightfully theirs. Until Europe can come up with a major tech company like Apple which designs, produces and markets like Apple do from the US, this will be petty jealousy.
Where were these profits reported as being earned?
Oh holy hell.
Accounting profit is not taxable profit. That is the case right now the smallest of companies.
Apple are going to be paying over 15% on nearly all of their overseas cash pile.
The ECJ would not allow the US to become an appelant in this case before because no money had been remitted to the US. Now the US stand to lose out on tax money as if Apple are forever to pay, it will be a tax credit.
The agreement between Apple, Ireland and the US was made under OECD rules. This is an EU tax grab. Corporation tax is about where value is created, the value is created in the United States.
Defending a Fine Gael tax policy is a lot like making love to a beautiful woman. You massage the figure, point to how itās stimulating growth, get your trousers taken down, and then you plough on into the fiscal space*.
*Or knowledge box, if you prefer.
Defending innovation and value is the whole point of OECD principles.
Avoiding tax is.
As far as I know Mike, tax avoidance is not illegal
Irish govt introduced legislation to make tax evasion legal for MNCs. EU have pulled us up on it. Their law trumps ours.
Wrong, wrong, wrong.
OECD principles are about trying to get people to pay tax where it is due.
Now with Apple, where is the value? When Apple sell a phone for several hundred euros where was that value created? The EU can crow all they like but we all know where and how Apple create their value, and itās not in Cork or Europe.
TP is an utter necessity for business to work across borders and markets. In this case; Apple, Ireland the US agreed on a TP arrangement.
Deary me
One could argue that the profit is created where the goods are sold.
You can dance on the head of a pin all you like, but itās true.
All these schemes are present entirely to enrich the owners of the company. Ireland or anywhere else facilitating it is simply allowing a company to avoid paying tax where the profit is made. This arguably impoverishes other nations in order to maintain the extreme wealth here.
Such is life.
If I made a product in ireland and sold it in the uk id be paying my tax in ireland. Doesnt matter where its sold.
The EU donāt agree with you.
It should do though. Itās back to whatās legal vs whatās morally right (if you believe that tax is a moral obligation)
So an Irish company who make a product in ireland but export it should pay tax where the product is sold? Bizarre. There would be vat and excise collected where its sold maybe but the profits on the sale rest with the company who sold it wherever thay may be
Incorrect.
Actually read what the OECD say on the arms length principle. Please donāt confuse VAT or payroll taxes for CT. CT is arguably already double taxation.
Let us break this down rationally. When a local Irish company sells into Europe, the Corporation Tax will be paid in Ireland unless they incorporate in that country. This is entirely fair. Why? Because thatās where the value was created. Whatever was created was done so in Ireland.
When Apple sell into Europe, fuck all value is created in Europe. Some bright spark in Silicon Valley designed the hardware after another created the tenchology. Another brightspark there designed the software. They hired brilliant designers. Another few smarty pants came up with a supply chain. They got together a crack team of marketers. Then they go off to some cheap location to manufacturer the actual product. Ireland, at the very end, the tiny portion of the wedge in the value chain, does some administration and logistical work. Tax should be paid on profits after you add back the royalties absolutely, but the substantial portion of that iPhone is an American product.
The double Irish was wrong, no question, but that is not actually the overall position here. The EU are attempting to supersede tax competency and international guidelines through one of their arms via State Aid.
Ultimately Apple will have paid over 20% of their profits over the last 7 or 8 years in Corporation Tax across the world once this money is remitted. Europe deserves fuck all of this money and whilst Apple absolutely exploited an aggressive loophole helped by Ireland, the meme that they have paid no tax is horseshit.
You keep barking that because you donāt have anything to add on the issue.
I can pipe back and say the OECD say very little of Appleās tax is due in Europe, that Ireland disagree, that the US disagrees and Apple themselves - but Iāve an actual argument of my own here and not just your tedious Ireland bashing.
Nonsense and gibberish.
Sweet Lord you are touchy on this. I have not debated the legality. Twisting the spirit of things suits a small tax haven like we are.
That is all.
Supercede.