Speaking on RTÉ Radio, Eamonn O’Dea, the head of Revenue’s global division, said the total tax to be paid “could be at that figure, at max [imum]”.
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“Apple has always been about doing the right thing, never the easy thing”.
Apple would fight closely with Ireland to overturn the ruling – by far the largest anti-competition measure imposed on a company by the European Union – which he said had “no basis in law or in fact”.
Earnest also warned that the billions in back taxes “could be treated in the US tax system as a current tax payment that would allow, essentially, Apple to deduct that European Union tax payment from their USA taxes”, a move he said would not be fair to American taxpayers.
“No one did anything wrong here and we need to stand together”.
USA companies are supposed to pay federal taxes on their global profits, but the tax on money made overseas is only due when it’s brought back to the U.S. Both Apple CEO Tim Cook and the Irish Finance Ministry said they plan to appeal that decision.
“The rulings endorsed a way to establish the taxable profits for two Irish incorporated companies of the Apple group (Apple Sales International and Apple Operations Europe), which did not correspond to economic reality: nearly all sales profits recorded by the two companies were internally attributed to a head office”, the statement further said.
However, the cabinet failed to agree on Wednesday whether to accept his recommendation due to misgivings among the five-strong Independent Alliance group of lawmakers.
“The big thing is to make sure the big corporations keep coming to Ireland”, said Conor Moran, 30, a software developer. “They don’t care about the normal people”, said Louise O’Reilly, 57, a full-time carer for her diabetic and partially blind mother. “They just picked a number from I don’t know where”, he said. Any failure of the Alliance to come on board would cast doubt on the government’s survival prospects.
Apple and Ireland both vowed to fight the decision in court.
“The future investment for business really depends on a level of certainty”, he told RTE radio.
In Washington, U.S. Treasury Secretary Jack Lew criticised the ruling. Cook has complained in the past that high US taxes have discouraged the company from bringing those earnings home. In a public letter to Apple customers on August 30, Cook wrote: “We are committed to Ireland and we plan to continue investing there, growing and serving our customers with the same level of passion and commitment”.
However, EU Competition Commissioner Margrethe Vestager said Ireland’s tax breaks meant that the company’s effective corporate tax rate on its European profits dropped from 1 percent in 2003 to a mere 0.005 percent in 2014. “And I think that (anti-U.S. sentiment) is one reason why we could have been targeted”.
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“We provisioned several billion dollars for the USA for payment as soon as we repatriate it and right now I forecast that repatriation to occur next year”, he told RTE.
