Apple shifted assets to island to evade tax scrutiny


The company is the largest private employer in Cork and economists estimate Apple's operations in Ireland generate around $24 billion annually in salaries, taxes and investment.

The European Commission has said Apple should pay €13 billion, plus interest, to Ireland, on untaxed income earned by Irish-incorporated Apple subsidiaries that were for a period of years stateless for tax purposes.

ASI had made more than $120bn (£91.52bn) - almost 60% of Apple's earnings worldwide - and had become their biggest profit generator, and most of the profits had been transferred to AOI as dividends. Apple has not made a figure available for its profits recorded in Ireland.

Baker McKenzie emailed several questionnaires to Appleby offices in notable offshore tax havens, including the Cayman Islands, the British Virgin Islands, Bermuda, Isle of Man, Guernsey and Jersey.

The iPhone maker eventually chose Jersey as its destination.

Apple moved to Jersey two of its key subsidiaries, Apple Sales International and Apple Operations International, while another structure, Apple Operations Ireland, became resident in Ireland.

By 2015, tighter Irish laws had caused all three to find a new tax home.

Vestager also said it was too early to say whether the latest leaks on tax arrangements by companies would lead to any general investigations.

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A clue as to why a multinational might want a subsidiary that was liable for taxes in Ireland can be found in Noonan's budget announcement in 2014. In the following Budget, it moved to shut down the so-called "Double Irish" tax avoidance strategy. Importantly for multinationals, it was also available to an Irish company that bought intangible property from another company within the same group.

A lawyer representing Hamilton insists the tax arrangement is legal.

Apple CEO Tim Cook was forced to defend Apple's tax practices in testimony to the U.S. Senate in 2013.

The European Union is now trying to force Ireland to collect €13 billion ($15 billion) in unpaid taxes from Apple.

The country's GDP for 2015 leapt by 26%, boosted by close to $270bn of intangible assets suddenly appearing in Ireland's national accounts at the start of the year.

"This rate has been consistent for many years", it added.

Apple moved the operation that holds most of its offshore cash out of Ireland to the Channel Island following a tax crackdown in the Republic. "The changes we made did not reduce our tax payments in any country".

Apple paid nearly no tax on earnings of more than $100bn over four years, US Senator Carl Levin and former presidential candidate John McCain claimed, although Apple mounted a strong defence. The selective treatment allowed Apple to pay an effective corporate tax rate of 1 percent on European profits in 2003, according to the commission previous year.