No you are confusing apple with Google or Amazon maybe. Possibly Starbucks. Apple doesn't licence any patents to Italian companies because all it does in Italy is sell stuff. You don't need to transfer IP to sell.
As for the 2% that's a matter of how the US and Ireland tax companies. The Irish tax 12.5% on sales if you are based and registered in Ireland. But only on Irish sales if you are based in the US, or outside the country but register in Ireland. The US taxes companies registered for tax and based there but doesn't tax companies based in the US but not registered there. One or the other should change but neither were set up to be a tax haven.
I think he means Apple US transfers IP to the Irish subsidiary to use in a Double-Irish tax avoidance plan. Apparently Apple confirmed some of the details during Senate hearings.
"The memorandum issued by the US Senate permanent subcommittee on investigations yesterday details how Apple transferred certain rights, including IP rights, to three Irish companies; Apple Sales International (ASI), Apple Operations Europe (AOE), and Apple Operations International (ASI), all of which have registered addresses in Cork but hold their board meetings in the US.
ASI buys finished product from a Chinese manufacturer and resells it at a profit to other Apple companies in jurisdictions outside the Americas without ever taking physical possession of the product. The resulting profit flow to Ireland in the 2009 to 2012 period was a phenomenal $74 billion. Because ASI is not managed and controlled in Ireland, it is not tax resident here. In fact, it is not tax resident anywhere.
This is because the US taxes companies on the basis of where they are registered as against where they are managed from."
Edited by Gatorguy - 11/13/13 at 12:10pm