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derriz, the ~0.005% taxes is not on revenue but on EU profits. How can you keep repeating your same mistake and keep burning through your karma? "After an inve

by JanSt 9y ago

derriz, the ~0.005% taxes is not on revenue but on EU profits. How can you keep repeating your same mistake and keep burning through your karma? "After an investigation, the EC determined that Apple, in accordance with the tax agreement with Ireland, had effectively paid annual taxes of 1.0% on its European profits in 2003 and ~0.005% in 2014." -marketrealist https://marketrealist.com/2018/01/eu-demanding-15-billion-unpaid-taxes-apple https://marketrealist.com/2018/01/eu-demanding-15-billion-un... How about you post some of your sources?

derriz 9y ago
JanSt it seems we are talking across each other so this will probably be my last post on the subject. The EC's determination is being challenged in court on the very basis that Vestager completely misunderstood or deliberately miscalculated what was "EU" profit. She basically claimed that Apple USA's intellectual property and management contributed nothing in generating profits on Apple sales in the EU. This is clear nonsense - without Apple USA, there would be zero "Apple" profits in the EU. Ask yourself a simple question; when Apple sells an iphone in Europe, say for say 600EUR excluding VAT or sales tax, how much of that profit "belongs" to the US operation and how much "belongs" to the European distribution center which happens to be based in Ireland? Vesteger's claim is that ALL OF IT belongs in Ireland. This claim will not last 10 minutes in front of the ECJ judges. The vast majority of it - according to decades of international tax case law - belongs to the Apple USA as they invented and developed the product. The product isn't even manufactured in Ireland. As a result of transfer pricing, the Irish distribution has very little profit to declare and so pays very little corporation tax. But this does NOT mean that Apple has avoided tax. They park their US profit in a Carribean bank account waiting for an opportune moment to repatriate it and when they do they pay corporate tax on it. The ironic aspect of this thing is that the US has the highest effective corporate tax rates in the OECD and so Apple would be far better off shifting as much of the profit as they can to Ireland. But they cannot because of international norm on transfer pricing.

by JanSt 9y ago

derriz 9y ago

JanSt it seems we are talking across each other so this will probably be my last post on the subject. The EC's determination is being challenged in court on the very basis that Vestager completely misunderstood or deliberately miscalculated what was "EU" profit. She basically claimed that Apple USA's intellectual property and management contributed nothing in generating profits on Apple sales in the EU. This is clear nonsense - without Apple USA, there would be zero "Apple" profits in the EU. Ask yourself a simple question; when Apple sells an iphone in Europe, say for say 600EUR excluding VAT or sales tax, how much of that profit "belongs" to the US operation and how much "belongs" to the European distribution center which happens to be based in Ireland? Vesteger's claim is that ALL OF IT belongs in Ireland. This claim will not last 10 minutes in front of the ECJ judges. The vast majority of it - according to decades of international tax case law - belongs to the Apple USA as they invented and developed the product. The product isn't even manufactured in Ireland. As a result of transfer pricing, the Irish distribution has very little profit to declare and so pays very little corporation tax. But this does NOT mean that Apple has avoided tax. They park their US profit in a Carribean bank account waiting for an opportune moment to repatriate it and when they do they pay corporate tax on it. The ironic aspect of this thing is that the US has the highest effective corporate tax rates in the OECD and so Apple would be far better off shifting as much of the profit as they can to Ireland. But they cannot because of international norm on transfer pricing.