You've misinterpreted what happens, I think Tim Cook was quite disingenuous about this.
Apple Operations International (Ireland) buys iPhones from Apple, or Foxconn in China at cost. Apple Operations International then sells those iPhones to Apple UK, Apple Germany, Apple France etc for close to the retail price. The local Apple Incs then sell the iphones to consumer or carriers. The local Apple Incs will pay sales tax, will have some staffing so will pay payroll taxes, but the amount of profit they book for selling iPhones will be absolutely minimal, and corporate tax for the local Apple Inc will also be minimal.
I'd like to see your evidence for this. For that matter, I'd like to see your evidence for ANY of the ridiculous claims you make.
You're talking about transfer pricing. Transfer pricing is regularly audited by the IRS and there are strict rules about how the transfer price must be set. If the IRS thinks Apple's transfer price is incorrect, they can challenge it. They have not done so. Furthermore, if the amount of profit Apple books in the US for selling iPhones is so small and if AOI sells the phones to Apple US for close to retail, how did they end up with $20 B in profits and $6 B in tax liability in the US?
You've misinterpreted what happens, I think Tim Cook was quite disingenuous about this.
Apple Operations International (Ireland) buys iPhones from Apple, or Foxconn in China at cost. Apple Operations International then sells those iPhones to Apple UK, Apple Germany, Apple France etc for close to the retail price. The local Apple Incs then sell the iphones to consumer or carriers. The local Apple Incs will pay sales tax, will have some staffing so will pay payroll taxes, but the amount of profit they book for selling iPhones will be absolutely minimal, and corporate tax for the local Apple Inc will also be minimal.
Apple Operations International meanwhile books Scrooge McDuck level of profit, since they sold the iPhones for so much more than they bought them, when it actually hasn't done anything in the real world. The iPhones were shipped from Foxconn to the local Apple Incs, AOI had no hand in anything except as a nebulous "owner" of the products for a short while. They have no staff, they have no overheads, and since through a curiosity of Irish Law they aren't "controlled" from within Ireland, they don't have to pay any corporation tax there.
Apple as a holistic entity has pretty much avoided paying any corporation tax in the EU. And it's entirely legal, which is why Tim cook is able to say that Apple pays all of its tax obligations with a straight face.
In answer to your question about whether Britain would allow this, Britain is basically king of the hill when it comes to allowing tax haven abuse. This country sold out to multinationals many years ago. Yes, we would allow this, we are allowing this, and under current policy directions it looks like it's only going to get worse.
*Obviously where I've said iPhones in the narrative above, you can take it to mean any Apple hardware product.
Well that would be a clever tactic if true. I would like to see your proof Apple Ireland does what you say. I for one would be surprised if it is the case. Tim's repeated assertion that the individual Apple HQs throughout Europe pay all their taxes would be disingenuous to an extreme to be sure and I would have thought very dangerous in front of a Senate hearing. I just can't believe Tim would put himself in that position.
So to be clear you are stating with certainty Apple UK, to take one example, purchases all it's Apple products from Ireland at almost full retail thus making zero profit in the UK. Does Apple UK publish its financials so we can see this?
Do you expect anyone to take you seriously when you say stupid shit like this?
People are getting a little flustered it seems, I thought a little brevity might lighten the tone. Apologies if its not to your tastes, we all have a different sense of humour.
People are getting a little flustered it seems, I thought a little brevity might lighten the tone. Apologies if its not to your tastes, we all have a different sense of humour.
Your "brevity" is on the order of
"My cat died."
"What a cat-astrophe!"
Just gonna copy/paste from Gatorguy's signature now:
"No theatrics and no more personal attacks, just stick to the logic and tell me why I don't have any argument"
One throwaway reference to Duck Tales was a theatric? Wow, your stage drama class must have been dull as hell.
I haven't made any personal attacks, that's entirely been you and the defenderati gang, and I haven't noticed you making any argument yet, so I'm not sure how I can respond.
One throwaway reference to Duck Tales was a theatric? Wow, your stage drama class must have been dull as hell.
I haven't made any personal attacks, that's entirely been you and the defenderati gang, and I haven't noticed you making any argument yet, so I'm not sure how I can respond.
Throw me a bone here.
You need to be blocked from posting in the tax threads.
Where have I lied? I haven't intended to lie anywhere, but I may have written something in error, and I'll apologise if that's the case. Please point out where you think I've said something false.
… Having subsidiaries in the countries in which it does business.
OOOHOOHOOHOOOOOO, so absurd¡
Take the rest of your political crap to PO.
Quote:
Originally Posted by Tallest Skil
Your "brevity" is on the order of
"My cat died."
"What a cat-astrophe!"
Just gonna copy/paste from Gatorguy's signature now:
"No theatrics and no more personal attacks, just stick to the logic and tell me why I don't have any argument"
Quote:
Originally Posted by Tallest Skil
You need to be blocked from posting in the tax threads.
Why are you having a go at Crowley? The above quotes have been your sum total input to this thread. Crowley, on the other hand, has provided facts backed up by evidence. Maybe if you tried to discuss things with him instead of making pointless comments these forums might by a better place to be.
I agree with you there, I'd prefer if there was only one thread. Or maybe two, one for the US repatriation issue and one for the EU avoidance issue, as I think there's been confusion between parties about what issue is being talked about.
It seems, like Levin and McCain you totally ignore the repeated testimony by Apple that the sales occur in the various countries in Europe where the appropriate taxes are paid on those profits. The net proceeds are then transferred to Ireland.
They said what they paid in income taxes - $900m, which is significantly below the Corporate Income Tax rates where they sell products. A 25% rate on their foreign profits is over $6b.
What part of 'the income has already been taxed' are you missing?
What you guys seem to be missing is that it has almost not been taxed at all - nowhere near the rate it should have been taxed. Tim calls it 'appropriate' but that's subjective. It doesn't get taxed again exactly because they get dollar for dollar tax credits against what they pay abroad.
Apple's argument is essentially that they've gone to all the trouble of avoiding paying taxes to foreign governments that paying repatriation would completely undo that effort. If they'd paid the 25% that they were supposed to, their repatriation rate would be 10%. If the US tax code matched the rest of the world at 25%, they'd pay 0% repatriation so long as they pay what they are due elsewhere.
Companies would rather avoid paying Corporation Tax altogether because that's the only real tax they suffer for. Employment taxes are taken from employees and sales tax is paid by customers. Property tax is small to a company like Apple:
"Oppenheimer: We paid $325m in federal employment taxes, in addition to our employees. We've paid $100 million to state and local governments in property taxes and other fees. Last year, we collected and remitted $1.3 billion in sales tax."
US revenues in 2012 were $57.5b so $1.3b is 2.2% effective sales tax. The US average was around 9.6%:
Do you think countries like Britain would allow Apple UK to collect revenues from sales tax free?
They said they paid overseas income tax, employment tax, sales tax and property tax all of which they are due to pay. They didn't disclose figures about the last 3 but made it clear the income tax is significantly below what it should be and you have to remember that it's customers that pay the sales tax directly, most of whom have no choice but to pay income tax at the full rate.
As Levin correctly pointed out, companies don't have the right to decide how much of each tax they should be paying. Customers don't get to decide how much sales tax to pay and their income tax is taken before they get their pay. The lowest earners and small businesses have little to no choice in the rates they pay but all of the big earners have lots of options and take advantage of them. The options should be eliminated but the options aren't always there for the purposes they are being used for so they add conditions and people find creative ways to get round the conditions and so on.
I agree with you there, I'd prefer if there was only one thread. Or maybe two, one for the US repatriation issue and one for the EU avoidance issue, as I think there's been confusion between parties about what issue is being talked about.
I'm still waiting for a response please (see a wee bit earlier up the page).
They said what they paid in income taxes - $900m, which is significantly below the Corporate Income Tax rates where they sell products. A 25% rate on their foreign profits is over $6b.
What you guys seem to be missing is that it has almost not been taxed at all - nowhere near the rate it should have been taxed. Tim calls it 'appropriate' but that's subjective. It doesn't get taxed again exactly because they get dollar for dollar tax credits against what they pay abroad.
Apple's argument is essentially that they've gone to all the trouble of avoiding paying taxes to foreign governments that paying repatriation would completely undo that effort. If they'd paid the 25% that they were supposed to, their repatriation rate would be 10%. If the US tax code matched the rest of the world at 25%, they'd pay 0% repatriation so long as they pay what they are due elsewhere.
Companies would rather avoid paying Corporation Tax altogether because that's the only real tax they suffer for. Employment taxes are taken from employees and sales tax is paid by customers. Property tax is small to a company like Apple:
"Oppenheimer: We paid $325m in federal employment taxes, in addition to our employees. We've paid $100 million to state and local governments in property taxes and other fees. Last year, we collected and remitted $1.3 billion in sales tax."
US revenues in 2012 were $57.5b so $1.3b is 2.2% effective sales tax. The US average was around 9.6%:
Sales tax is calculated based on shipping address through Apple's online store. Maybe they just get a lot of customers in Delaware or Oregon.
They said they paid overseas income tax, employment tax, sales tax and property tax all of which they are due to pay. They didn't disclose figures about the last 3 but made it clear the income tax is significantly below what it should be and you have to remember that it's customers that pay the sales tax directly, most of whom have no choice but to pay income tax at the full rate.
As Levin correctly pointed out, companies don't have the right to decide how much of each tax they should be paying. Customers don't get to decide how much sales tax to pay and their income tax is taken before they get their pay. The lowest earners and small businesses have little to no choice in the rates they pay but all of the big earners have lots of options and take advantage of them. The options should be eliminated but the options aren't always there for the purposes they are being used for so they add conditions and people find creative ways to get round the conditions and so on.
I am ready to accept any scenario based on proof. Do you have access to a link for the Apple UK financials showing almost no tax on sales due to purchasing from Ireland at almost retail prices as some here are claiming. I have to see this for myself.
On your point about individuals tax options (last paragraph) I would have to say it seems Americans have many, many options. Raging in extremes from living of earned interest alone to driving to New Hampshire to buy something. Plus those of us that are self employed don't have income taxes removed up front. Just saying ...
I'm still waiting for a response please (see a wee bit earlier up the page).
Does the post underneath yours not satisfy this?
Apple Inc doesn't do any country-by-country reporting to my knowledge. It would be very helpful if they did.
if you need more, I'll do my best, but as is the nature with tax havens and transfer pricing, the details can be hard to pin down; that's why we have things like Senate Hearings to draw them out
Comments
Forbes has a nice article about how well Tim Cook did in representing Apple's position while under fire from the Senate committee.
http://www.forbes.com/sites/carminegallo/2013/05/21/its-important-to-tell-our-story-5-ways-apples-tim-cook-stayed-cool-under-fire/
Quote:
Originally Posted by Crowley
Apple Operations International meanwhile books Scrooge McDuck level of profit...
Do you expect anyone to take you seriously when you say stupid shit like this?
I'd like to see your evidence for this. For that matter, I'd like to see your evidence for ANY of the ridiculous claims you make.
You're talking about transfer pricing. Transfer pricing is regularly audited by the IRS and there are strict rules about how the transfer price must be set. If the IRS thinks Apple's transfer price is incorrect, they can challenge it. They have not done so. Furthermore, if the amount of profit Apple books in the US for selling iPhones is so small and if AOI sells the phones to Apple US for close to retail, how did they end up with $20 B in profits and $6 B in tax liability in the US?
This is not about the US, this is about the EU and Ireland. Nowhere in the comment above have I even mentioned the US.
Well that would be a clever tactic if true. I would like to see your proof Apple Ireland does what you say. I for one would be surprised if it is the case. Tim's repeated assertion that the individual Apple HQs throughout Europe pay all their taxes would be disingenuous to an extreme to be sure and I would have thought very dangerous in front of a Senate hearing. I just can't believe Tim would put himself in that position.
So to be clear you are stating with certainty Apple UK, to take one example, purchases all it's Apple products from Ireland at almost full retail thus making zero profit in the UK. Does Apple UK publish its financials so we can see this?
It's pretty comprehensively covered in the Senate Hearing Report: http://www.hsgac.senate.gov/subcommittees/investigations/hearings/offshore-profit-shifting-and-the-us-tax-code_-part-2
Business Insider have written it up in an easy to understand report: http://www.businessinsider.com/how-apple-reduces-what-it-pays-in-taxes-2013-5
Not much of this is new information by the way, it was covered extensively in the British press last November:
http://www.bbc.co.uk/news/business-20197710
http://www.telegraph.co.uk/finance/newsbysector/mediatechnologyandtelecoms/9653961/Apple-pays-less-than-2pc-tax-on-overseas-profits.html
http://www.guardian.co.uk/technology/2012/nov/04/apple-paid-low-overseas-tax
It's not hard to find plenty more articles from left-wing and right wing sources
Quote:
Originally Posted by MJ1970
Do you expect anyone to take you seriously when you say stupid shit like this?
People are getting a little flustered it seems, I thought a little brevity might lighten the tone. Apologies if its not to your tastes, we all have a different sense of humour.
Originally Posted by Crowley
People are getting a little flustered it seems, I thought a little brevity might lighten the tone. Apologies if its not to your tastes, we all have a different sense of humour.
Your "brevity" is on the order of
"My cat died."
"What a cat-astrophe!"
Just gonna copy/paste from Gatorguy's signature now:
"No theatrics and no more personal attacks, just stick to the logic and tell me why I don't have any argument"
One throwaway reference to Duck Tales was a theatric? Wow, your stage drama class must have been dull as hell.
I haven't made any personal attacks, that's entirely been you and the defenderati gang, and I haven't noticed you making any argument yet, so I'm not sure how I can respond.
Throw me a bone here.
Originally Posted by Crowley
One throwaway reference to Duck Tales was a theatric? Wow, your stage drama class must have been dull as hell.
I haven't made any personal attacks, that's entirely been you and the defenderati gang, and I haven't noticed you making any argument yet, so I'm not sure how I can respond.
Throw me a bone here.
You need to be blocked from posting in the tax threads.
Sigh. Dissenting opinions must be silenced, hey?
Disappointing that you'd even suggest that.
If you don't like what I'm writing, ignore it. It's easy.
Originally Posted by Crowley
Dissenting opinions must be silenced, hey?
No, just lies.
Where have I lied? I haven't intended to lie anywhere, but I may have written something in error, and I'll apologise if that's the case. Please point out where you think I've said something false.
Quote:
Originally Posted by Tallest Skil
… Having subsidiaries in the countries in which it does business.
OOOHOOHOOHOOOOOO, so absurd¡
Take the rest of your political crap to PO.
Quote:
Originally Posted by Tallest Skil
Your "brevity" is on the order of
"My cat died."
"What a cat-astrophe!"
Just gonna copy/paste from Gatorguy's signature now:
"No theatrics and no more personal attacks, just stick to the logic and tell me why I don't have any argument"
Quote:
Originally Posted by Tallest Skil
You need to be blocked from posting in the tax threads.
Why are you having a go at Crowley? The above quotes have been your sum total input to this thread. Crowley, on the other hand, has provided facts backed up by evidence. Maybe if you tried to discuss things with him instead of making pointless comments these forums might by a better place to be.
Originally Posted by reefoid
The above quotes have been your sum total input to this thread. Crowley, on the other hand, has provided facts backed up by evidence.
Tends to get confusing when they split it between ten threads.
Facts, huh.
I agree with you there, I'd prefer if there was only one thread. Or maybe two, one for the US repatriation issue and one for the EU avoidance issue, as I think there's been confusion between parties about what issue is being talked about.
They said what they paid in income taxes - $900m, which is significantly below the Corporate Income Tax rates where they sell products. A 25% rate on their foreign profits is over $6b.
What you guys seem to be missing is that it has almost not been taxed at all - nowhere near the rate it should have been taxed. Tim calls it 'appropriate' but that's subjective. It doesn't get taxed again exactly because they get dollar for dollar tax credits against what they pay abroad.
Apple's argument is essentially that they've gone to all the trouble of avoiding paying taxes to foreign governments that paying repatriation would completely undo that effort. If they'd paid the 25% that they were supposed to, their repatriation rate would be 10%. If the US tax code matched the rest of the world at 25%, they'd pay 0% repatriation so long as they pay what they are due elsewhere.
Companies would rather avoid paying Corporation Tax altogether because that's the only real tax they suffer for. Employment taxes are taken from employees and sales tax is paid by customers. Property tax is small to a company like Apple:
"Oppenheimer: We paid $325m in federal employment taxes, in addition to our employees. We've paid $100 million to state and local governments in property taxes and other fees. Last year, we collected and remitted $1.3 billion in sales tax."
US revenues in 2012 were $57.5b so $1.3b is 2.2% effective sales tax. The US average was around 9.6%:
http://www.forbes.com/sites/williampbarrett/2012/02/02/average-u-s-sales-tax-rate-drops-a-little/
Sales tax is calculated based on shipping address through Apple's online store. Maybe they just get a lot of customers in Delaware or Oregon.
They said they paid overseas income tax, employment tax, sales tax and property tax all of which they are due to pay. They didn't disclose figures about the last 3 but made it clear the income tax is significantly below what it should be and you have to remember that it's customers that pay the sales tax directly, most of whom have no choice but to pay income tax at the full rate.
As Levin correctly pointed out, companies don't have the right to decide how much of each tax they should be paying. Customers don't get to decide how much sales tax to pay and their income tax is taken before they get their pay. The lowest earners and small businesses have little to no choice in the rates they pay but all of the big earners have lots of options and take advantage of them. The options should be eliminated but the options aren't always there for the purposes they are being used for so they add conditions and people find creative ways to get round the conditions and so on.
I'm still waiting for a response please (see a wee bit earlier up the page).
I am ready to accept any scenario based on proof. Do you have access to a link for the Apple UK financials showing almost no tax on sales due to purchasing from Ireland at almost retail prices as some here are claiming. I have to see this for myself.
On your point about individuals tax options (last paragraph) I would have to say it seems Americans have many, many options. Raging in extremes from living of earned interest alone to driving to New Hampshire to buy something. Plus those of us that are self employed don't have income taxes removed up front. Just saying ...
Quote:
Originally Posted by digitalclips
I'm still waiting for a response please (see a wee bit earlier up the page).
Does the post underneath yours not satisfy this?
Apple Inc doesn't do any country-by-country reporting to my knowledge. It would be very helpful if they did.
if you need more, I'll do my best, but as is the nature with tax havens and transfer pricing, the details can be hard to pin down; that's why we have things like Senate Hearings to draw them out