While this sandwich structure is in principle highly problematic it is legal. Reading the complaint there is a lot in it about valuation of the intra-company t

While this sandwich structure is in principle highly problematic it is legal. Reading the complaint there is a lot in it about valuation of the intra-company transfers and arms length principle in establishing valuation numbers. I suspect it is there where Ireland and Apple colluded to enable Apple to avoid paying taxed in other EU states. Apple may be saying it is legal but they must know that the deal they got from the Irish Government was too good to be true. While the volume was small it did not raise alarm bells but the volume Apple is doing it eventually pushed the envelope too far.