The more I read about this the more likely I think this decision could be appealed and overturned. The initial implication is that Apple specially negotiated a

The more I read about this the more likely I think this decision could be appealed and overturned. The initial implication is that Apple specially negotiated a lower tax rate for itself in Ireland. But if you read through the European Commission press release[1], it's not that a special rate was negotiated, but rather Apple Sales International (the Irish Subsidiary) only pays Irish income tax on the portion of its income that comes from within Ireland, which is correct according to Irish tax law. But there's nothing particularly special about this setup that applies only to Apple, and from what I can tell, any other corporation operating in Ireland could have also set up this arrangement and is subject to the same rules. It doesn't make sense to me that the EU can compel Ireland to collect more taxes from Apple, if according to Irish tax law, they've already paid what they owe for Irish sales, and they don't owe taxes for non-Irish sales. Now, there is a separate question, which is can/should every other EU country go after Apple's local subsidiaries for failing to pay sufficient income tax in their own countries (by transferring the profits over to Ireland)? The answer to that is probably yes. If Apple sells an iPhone in Italy for a profit, it should pay Italian taxes on those profits, and should not be able to avoid Italian taxes by booking the profit in Ireland. This is touched upon in the press release: > The amount of unpaid taxes to be recovered by the Irish authorities would be reduced if other countries were to require Apple to pay more taxes on the profits recorded by Apple Sales International and Apple Operations Europe for this period. This could be the case if they consider, in view of the information revealed through the Commission’s investigation, that Apple's commercial risks, sales and other activities should have been recorded in their jurisdictions. This is because the taxable profits of Apple Sales International in Ireland would be reduced if profits were recorded and taxed in other countries instead of being recorded in Ireland. It seems more logical to me to conclude that that Apple doesn't owe more taxes to Ireland, instead they owe more taxes to all the other countries in the world where they operate but have avoided taxes by transferring their profits into Ireland. [1] http://europa.eu/rapid/press-release_IP-16-2923_en.htm http://europa.eu/rapid/press-release_IP-16-2923_en.htm