The Commission says the tax structure is outside the remit of European Union state aid control, but it goes on to say that if other countries were to require Apple to pay more tax on profits of the two companies over the same period under their national taxation rules, this would reduce the amount to be recovered by Ireland.
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“We paid $400m to Ireland, we paid $400 (million) to the USA and 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”, Cook said. In this vein, responding to the question of whether Apple has anything to apologize for or if it did anything wrong, Cook said succinctly “no, we haven’t done anything wrong”.
In Apple CEO Tim Cook’s view, it’s “total political crap”. As such, the company allegedly paid a tax rate of 0.005 percent in Ireland throughout 2014 – a figure Cook said is “false” and he has “no idea where the number came from”. “In Ireland and in every country where we operate, Apple follows the law and we pay all the taxes we owe”.
The company reported in 2014 an effective tax rate of 26.1% on its world-wide profits, including the foreign tax provisions that are unpaid, a level Mr. Cook described as “reasonable”.
She said Apple’s sweetheart tax deal with Ireland amount to “illegal state aid”. Apple immediately refuted any wrongdoing and has already said the Irish government will appeal.
He added: ” I think both parties feel like the decision is wrong, is not based on law or facts. However, Cook insisted that Apple and Ireland had “played by the rules” and would win the case on appeal.
“Apple has more subsidiaries in Ireland, as indicated in the Commission’s decision to open an investigation. We believe we’re the largest taxpayer there”.
Telling RTE that he “profoundly” disagreed with the decision, Noonan said: “The decision leaves me with no choice but to seek cabinet approval to appeal”.
All of Apple’s business outside of the Americas is conducted through Ireland, which has the second-lowest corporate tax rate in Europe.
The EU has also ordered Starbucks to pay more taxes to the Netherlands.
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“In Apple’s case, almost all of our research and development takes place in California, so the vast majority of our profits are taxed in the U.S. European companies doing business in the U.S. are taxed according to the same principle”.
