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I7guy

macrumors Nehalem
Nov 30, 2013
34,313
24,050
Gotta be in it to win it
Let the non-EU world develop its efficient Intel alternative without ARM or ASML. Good luck, too.
Israel has a pretty good grip on chip design.
Everyone can play the petulant child on the forums. Companies tend to count to ten rather than shooting from the hip.
Like the Facebook threat of leaving the UK?
 

Lioness~

macrumors 68040
Apr 26, 2017
3,026
3,753
Sweden
There must be some small and cheap country Timmy and Apple can buy, right.
Or get on the good side with the Pope, and move their taxes to the Vatican 😂
 

Lioness~

macrumors 68040
Apr 26, 2017
3,026
3,753
Sweden
Apple are not even having a store in the tax-haven Monaco - what are they thinking?
Ah well, I have a hard time imagine Prince Albert hanging with Timmy.
 
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bollman

macrumors 6502a
Sep 25, 2001
679
1,458
Lund, Sweden
You took the misleading numbers at face value. The stateless revenue was used to delay taxes on US revenue. Not to avoid EU taxes.

The EU numbers are misleading because they are based on the ridiculous assumption that all revenue generated in the EU is booked in the EU. Apple, in accordance with international tax law, believes that most of the money should be taxed in the U.S. where the value is generated. They use their "stateless" corporation to hold the money until it is repatriated. The deferred payments for U.S. taxes on these funds are included in their financial statements.
Ridiculous assumption?
The "International tax law" you refer to is the DTA between Ireland and US from 1997 I guess, and is very specific to taxation between Ireland and the US.
This is a very complex set of rules that make law firms rich. I highly doubt you, or I, have the qualifications to fully understand all implications of that DTA. It still stipulates that companies can decide to pay tax in Ireland or the US, not "nowhere".

Yes repatriating money is a thing, but that usually means that US companies can bring home profits already taxed in another country. Sort of a special, limited time offer of a DTA for all the world. US already has a DTA with Ireland, Apple does not need to tax their profit in Ireland, they only need to pay US tax. Or, if they pay tax in Ireland, they do not need to pay tax in the US. With this setup, Apple does not tax anything in Ireland, then they wait until US gives a DTA with "nowhere" and pays tax nowhere. Not cool. And only possible with the help of Ireland, now found in the wrong.

Tax is something you, I and companies pay yearly on our yearly income/profit, you can't just hold your profits somewhere in wait on getting a better deal. Under the DTA you either pay tax in the US or Ireland, not "nowhere".
The country of Ireland helped Apple acheive this and are therefore in the wrong by giving Apple ways to avoid tax.

Also, read the entire press release. Other countries found to have given illegal state aid are Netherlands and Luxembourg where Fiat, Amazon, McDonalds and Starbucks have recieved illegal aid and had to pay. It is not a crusade against Apple as some think here.
 
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Gudi

Suspended
May 3, 2013
4,590
3,265
Berlin, Berlin
Apple are not even having a store in the tax-haven Monaco - what are they thinking?
Ah well, I have a hard time imagine Prince Albert hanging with Timmy.
Come on, they settled in a country traumatized by mass starvation. It was a good strategy to pick the country with the lowest corporate tax rate in Europe and then bully its weak government into paying no taxes at all. And they would have gotten away with it, if it wasn't for this 'Total Political Crap'! 😆 🇪🇺

 
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Lioness~

macrumors 68040
Apr 26, 2017
3,026
3,753
Sweden
If only EU could come up with a law that made it possible to use any phone with iOS.
That could be interesting 🤔

There’s a bunch of sweet phones/phablets or maybe even computers that I would test if I still could
use an OS on my devices that were speaking and dancing with each other well.
 
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Gudi

Suspended
May 3, 2013
4,590
3,265
Berlin, Berlin
Ok. We'll wait patiently.
No need to wait. US airplanes fall from the sky, US food makes you obese. If it wasn't for Apple and Netflix, we wouldn't have any use for American products and then there would be no point in further engaging in world trade and exporting European goods to the US either. We need you to keep making the few products, which you're genuinely good at making. Nobody is trying to replace Americans as software engineers and screen writers. The division of labor and specialization of trades raises everybody's living standard around the world. The EU just tells your mega tech corporations, which business practices should and shouldn't be legal in a functional market economy. It's what the US government would do too, if it wasn't a failed state blocked by Republican partisanship. The 1% won't allow Americans to have a real democracy with primacy of politics over capital interests. That's fine your continent has long been lost. Just don't think threatening to take away our Facebook is some kind of leverage on Brussels to become like Washington.
 

Apple Fan 2008

macrumors 65816
May 17, 2021
1,424
3,452
Florida, USA 🇺🇸
If only EU could come up with a law that made it possible to use any phone with iOS.
That could be interesting 🤔
Apple would just say this:
A12E8668-13AD-4CBB-ABA0-A8168D24A75F_1_201_a.jpeg
 

BaldiMac

macrumors G3
Jan 24, 2008
8,795
10,933
Ridiculous assumption?
The "International tax law" you refer to is the DTA between Ireland and US from 1997 I guess, and is very specific to taxation between Ireland and the US.
I wasn't referring to any specific agreement. But DTAs are hardly specific to the US and Ireland. The US has similar agreements with dozen of countries. Most developed countries recognize through various tax treaties and agreements that most revenue is booked in the country where the value is created. For Apple, that is the US.

That the EU would put out numbers that assume all revenue should be booked in the EU is, as I said, ridiculous and misleading.

This is a very complex set of rules that make law firms rich. I highly doubt you, or I, have the qualifications to fully understand all implications of that DTA. It still stipulates that companies can decide to pay tax in Ireland or the US, not "nowhere".
The tax is paid in the US. Not "nowhere". Again, the Irish tax arrangement just allows Apple to delay paying US taxes. The EU isn't losing anything.

Yes repatriating money is a thing, but that usually means that US companies can bring home profits already taxed in another country.
Not taxed profits. Untaxed revenue.
 

laptech

macrumors 68040
Apr 26, 2013
3,601
4,006
Earth
What I find ironic is that when the case was first reported on, people in the know about financial matters and taxes said the EU had a strong case against Apple but as the years went on and the case finally went to court, Apple won and now here with have a advocate-general of the European Court of Justice (ECJ) saying there was errors in the case which probably allowed Apple to win.

Errors in court cases happen all the time resulting in re-trials. So why can't Apple be re-tried if there was errors in the case?
 

H2SO4

macrumors 603
Nov 4, 2008
5,674
6,953
Not as far as technology. Or if another country invades them. Then we're suddenly their best friend begging us to bail them out.
That sounds like a delusion.
The US have the best record of the instance of friendly fire.
 

H2SO4

macrumors 603
Nov 4, 2008
5,674
6,953
Did you forget WWI and WWII? Seems like you did.
No. Also I’m done with this.
It’s fallacy. The US helped in that war and you can speculate but you don’t really know what would have happened if they didn’t.
Also, more importantly, (and honestly), it was a joint effort.
The others didn’t go and sit at home until Uncle Sam was done sorting it out on his own. Did they.
 
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bollman

macrumors 6502a
Sep 25, 2001
679
1,458
Lund, Sweden
I wasn't referring to any specific agreement. But DTAs are hardly specific to the US and Ireland. The US has similar agreements with dozen of countries. Most developed countries recognize through various tax treaties and agreements that most revenue is booked in the country where the value is created. For Apple, that is the US.

That the EU would put out numbers that assume all revenue should be booked in the EU is, as I said, ridiculous and misleading.


The tax is paid in the US. Not "nowhere". Again, the Irish tax arrangement just allows Apple to delay paying US taxes. The EU isn't losing anything.


Not taxed profits. Untaxed revenue.

I would like to see some sources to back up your claim on how taxation works.

"International Tax Law" is a subject you can study:
It deals with "taxation in cross border situations". There are no universal laws regarding taxes. What governing body would oversee that? The UN? The best (but not the only thing) you can get are DTAs, and Ireland is one of few, if not the only EU country to have a DTA with USA. That is one of the reasons so many US companies have their EU businesses setup in Ireland.
Most countries actually insists on territorial tax, that is: profits are taxed in the country where profits are made.

Again, read the article about "Double Irish":

It is profits that are taxed not revenue. From the article about double Irish: "The US was one of a small number of countries that did not use a "territorial" tax system, and taxed corporations on all profits, no matter whether the profit was made outside the US or not, in contrast to "territorial" tax systems which tax only profits made within that country."
Observe the US anomaly of non-territorial tax, and that PROFITS are taxed, not revenue.

I mean, come on, even a bipartisan senate committee found that Apple was avoiding taxation:
 

BaldiMac

macrumors G3
Jan 24, 2008
8,795
10,933
I would like to see some sources to back up your claim on how taxation works.

"International Tax Law" is a subject you can study:
It deals with "taxation in cross border situations". There are no universal laws regarding taxes. What governing body would oversee that? The UN? The best (but not the only thing) you can get are DTAs, and Ireland is one of few, if not the only EU country to have a DTA with USA. That is one of the reasons so many US companies have their EU businesses setup in Ireland.
Most countries actually insists on territorial tax, that is: profits are taxed in the country where profits are made.

Again, read the article about "Double Irish":

It is profits that are taxed not revenue. From the article about double Irish: "The US was one of a small number of countries that did not use a "territorial" tax system, and taxed corporations on all profits, no matter whether the profit was made outside the US or not, in contrast to "territorial" tax systems which tax only profits made within that country."
Observe the US anomaly of non-territorial tax, and that PROFITS are taxed, not revenue.
I’m well aware of how the double Irish works. It’s like you said I was wrong and then listed a bunch of facts that didn’t dispute what I said.

I mean, come on, even a bipartisan senate committee found that Apple was avoiding taxation:
It’s certainly a reasonable opinion. Not sure why you think I would disagree with that. Like I said, they are using it to delay paying US taxes. Not avoiding EU taxes.
 

Gudi

Suspended
May 3, 2013
4,590
3,265
Berlin, Berlin
Privatize it all. Government only creates waste, fraud and abuse. Take a look at the Boston Big Dig for example...
Why don’t you play Guinea Pig for this social experiment? 🐹 🇺🇸

And we follow the tried and trusted way of the Roman Empire’s road building funding. 🇮🇹 🏟️ 🇪🇺
 
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