Ireland expected to dissolve 'Double Irish' tax loophole benefitting Apple, others

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  • Reply 41 of 107
    Quote:
    Originally Posted by ClemyNX View Post

     

     

    No big loss. They are part of the UE and they have to play by the rules.




    I disagree with this too. It will be a huge loss to Ireland. It just is, probably, a smaller loss than leaving the EU in the first place. Also, moved to Berlin? Like it?

  • Reply 42 of 107
    Marvin wrote: »
    They'll still have one of the lowest corporate tax rates in the world without using loopholes. The US is the worst so companies should really all leave the US and go to any EU country:

    http://taxfoundation.org/article/us-states-lead-world-high-corporate-taxes
    http://www.kpmg.com/global/en/services/tax/tax-tools-and-resources/pages/corporate-tax-rates-table.aspx

    Montenegro is only 9% and is very picturesque:

    1000
    I think it would have to be more than consumption tax. You could effectively trade in virtual assets like stocks and shares and not pay any tax at all outside of your own living expenses.

    To make it fair, they'd also have to eliminate the personal equivalent, which is income tax. Corporation tax is just income tax for corporations.

    I think it's something that should be explored because income, sales and corporation taxes more than anything place an administrative burden on businesses. The banks can all see where the money is going, the majority of transactions are digital. That data can be used to work out a reasonable share to take based on the movement of money and it doesn't need to use confusing time periods like offset quarters or years. If it's done during transactions, you can see how much is coming off so there's no provisions or deferments for tax needed.

    I recommend Uruguay. They're working on their own Bitcoin-based economy (last I heard). Apple Pay the whole country could be nice.
  • Reply 43 of 107
    asdasdasdasd Posts: 5,686member

    Assuming Apple want to be in Europe I don't forsee any exodus from Ireland, unless other costs in Ireland are too onerous. Apple just now have to pay 12.5% to the Irish revenue, rather than 20+% elsewhere in Europe. This doesn't stop that. 

  • Reply 44 of 107
    Quote:

    Originally Posted by asdasd View Post

     

    Assuming Apple want to be in Europe I don't forsee any exodus from Ireland, unless other costs in Ireland are too onerous. Apple just now have to pay 12.5% to the Irish revenue, rather than 20+% elsewhere in Europe. This doesn't stop that. 




    Anyway, it's not only about the tax rate itself, it's also about the advantages or inconveniences. Being close to the UK, for example, or being in a multicultural economy like in Amsterdam, or being in a picturesque place like Montenegro (lol, good one), or having Brian May as a neighbour like in the Island of Man, or whatever else a big corporation feels makes them more money or less expenses.

  • Reply 45 of 107
    dasanman69dasanman69 Posts: 13,002member
    solipsismx wrote: »
    The part that gets me is that no less than 3 "leaders of the free world" have paid this guy $250,000 to own land on the moon.

    I guess the world is free, but the moon isn't. ;)
  • Reply 46 of 107
    Considering the woeful state Ireland's been in, you'd think a coalition of all the large businesses located there could buy the entire country, declare legal independence from the EU, and go about their business.
  • Reply 47 of 107
    Quote:

    Originally Posted by SolipsismX View Post





    Can you explain?

     

    Don't see anyone else follow up on this, so here goes.

     

    Apple pays taxes in every country where it sells products.  For example, Apple sells an iPhone in Germany, they pay tax on the profit to Germany.  The remaining profit is then sent off to Ireland for holding, since the Ireland didn't require taxes for corporations that we're registered in Ireland.

     

    And that money can then be used to build stores in Europe without having to transfer money from the US.

     

    Now, what most corporations want to avoid is the repatriation tax that would occur if they transfer the money back to the US entity.  If they wanted to use the profits from Europe in the US, they would have to transfer that money back to the US and pay roughly 30% tax on it.  That's the money that US senators are salivating over and bitching because they can't get it into their coffers.  

     

    It's essentially a double tax on the money.  Taxed in the country the product was sold.  Taxed when the money comes back to the US.

     

    Think of it in these terms:  You're a US citizen.  You go to Europe and work for a year.  You're paying local taxes on your income.  When you return to the US and fill out your tax forms, the US asks if you earned income outside of the US and how much you paid in taxes.  If you paid more then the US requires, then you don't need to pay additional taxes.

     

    However, for a corporation, they still have to pay taxes on it.  So if Europe takes 20% corporate profit tax for each country and then the US takes 30%...

     

    At least that's my partial understanding of the situation.  Obviously the way products to sell flow is a whole other area of discussion.

  • Reply 48 of 107
    thefly wrote: »
    Don't see anyone else follow up on this, so here goes.

    Apple pays taxes in every country where it sells products.  For example, Apple sells an iPhone in Germany, they pay tax on the profit to Germany.  The remaining profit is then sent off to Ireland for holding, since the Ireland didn't require taxes for corporations that we're registered in Ireland.

    And that money can then be used to build stores in Europe without having to transfer money from the US.

    Now, what most corporations want to avoid is the repatriation tax that would occur if they transfer the money back to the US entity.  If they wanted to use the profits from Europe in the US, they would have to transfer that money back to the US and pay roughly 30% tax on it.  That's the money that US senators are salivating over and bitching because they can't get it into their coffers.  

    It's essentially a double tax on the money.  Taxed in the country the product was sold.  Taxed when the money comes back to the US.

    Think of it in these terms:  You're a US citizen.  You go to Europe and work for a year.  You're paying local taxes on your income.  When you return to the US and fill out your tax forms, the US asks if you earned income outside of the US and how much you paid in taxes.  If you paid more then the US requires, then you don't need to pay additional taxes.

    However, for a corporation, they still have to pay taxes on it.  So if Europe takes 20% corporate profit tax for each country and then the US takes 30%...

    At least that's my partial understanding of the situation.  Obviously the way products to sell flow is a whole other area of discussion.

    AFAIK, US citizens working outsude the US are taxed twice (once overseas and once by the U.S. govt). I cannot cite chapter and verse, but I recall seeing complaints to this effect.
  • Reply 49 of 107
    croprcropr Posts: 1,124member
    Quote:
    Originally Posted by blazar View Post



    I would prefer zero international and national corporate taxes since all they do is increase the proce of products for the consumer anyway. The consumer (aka the public) doesnt really get anything out of corporate taxes except a reduction in purchasing power of their money.

    Taxes on calculated on profits.  Corporate tax does not increase the cost, nor does it change the selling price,  it just decreases the profit made by a company.  The impact on the consumer price is by definition zero.

  • Reply 50 of 107
    maestro64maestro64 Posts: 5,043member
    Quote:

    Originally Posted by john12345 View Post



    Blame the EU. Their economy is going down the drain and so they need to leech off Apple.

    This is exactly what is going on. the question is, will Ireland really follow through. Ireland and Apple has had a long relationship unlike google and others who just happen to jump on the bandwagon recently.

     

    As the article state all the Irish money does not stay in Ireland it all is funnel to the Cayman Island, Apple was one of the first US company to set up it offshore business in the Cayman Island. This has been a blessing and curse to them, back in the 90's when they were hurting for money they have Billions sitting in the Cayman island but did not want to bring it onshore since they were going to pay huge taxes.

  • Reply 51 of 107
    asdasdasdasd Posts: 5,686member

    The best thing the EU should do if it wants to survice 

    Quote:
    Originally Posted by lightknight View Post

     



    Anyway, it's not only about the tax rate itself, it's also about the advantages or inconveniences. Being close to the UK, for example, or being in a multicultural economy like in Amsterdam, or being in a picturesque place like Montenegro (lol, good one), or having Brian May as a neighbour like in the Island of Man, or whatever else a big corporation feels makes them more money or less expenses.




    Yes, and of course just being there. The stickiness of having sunk capital and a workforce in a place. Apparently the workforce in Cork is about 50% non-Irish so it could theoretically go anywhere but the exodus in the EU is East West and South North not the other way around. Everybody thinks lower wages matter but not if you are attracting people from anywhere.

     

    Not that I would complain about Spain. I'd prefer Spain to Cork were I to apply for Apple.

  • Reply 52 of 107
    croprcropr Posts: 1,124member
    Quote:

    Originally Posted by asdasd View Post

     

    Assuming Apple want to be in Europe I don't forsee any exodus from Ireland, unless other costs in Ireland are too onerous. Apple just now have to pay 12.5% to the Irish revenue, rather than 20+% elsewhere in Europe. This doesn't stop that. 




    Apple is concentrating all its EU profits in Ireland (this is perfectly fine under the EU law), so it will pay 12,5% on the EU profit, and not on EU revenue, as corporate taxes are imposed on profits.

  • Reply 53 of 107
    asdasdasdasd Posts: 5,686member
    Quote:

    Originally Posted by SpamSandwich View Post





    AFAIK, US citizens working outsude the US are taxed twice (once overseas and once by the U.S. govt). I cannot cite chapter and verse, but I recall seeing complaints to this effect.



    No there is a double taxation agreement, as there is for US corporations. The senate committee got that totally wrong. It can be argued that tax should be paid where IP is generated but that is not now international law. The Senate accused Apple of avoiding tax in the US by avoiding tax in Europe, in fact Apple owes more back tax to the US because of it's low tax payments in Ireland. This is what they mean by their "effective tax rate" on all conference calls. Its about 26% which indicates a desire to repatriate at some time.

  • Reply 54 of 107
    asdasdasdasd Posts: 5,686member
    Quote:
    Originally Posted by cropr View Post

     



    Apple is concentrating all its EU profits in Ireland (this is perfectly fine under the EU law), so it will pay 12,5% on the EU profit, and not on EU revenue, as corporate taxes are imposed on profits.




    I didn't say it was 12.5% on Apple's revenue but that they would be paying to Revenue. Which is the Irish IRS. 

  • Reply 55 of 107
    croprcropr Posts: 1,124member
    Quote:

    Originally Posted by anantksundaram View Post





    You're missing his point. The fact is, regardless of what you think, corporations do not pay taxes; you and I do. Almost all of it is passed though to us. Corporations are no more than a vehicle for tax collection.



    The government is bamboozling people into believing that there is some corprate entity that is separate from its tax-paying customers. That's pure fiction. You can choose to believe it if you wish.

     

    I own a little software company and the company does pay a corporate tax on the profits it makes, which has nothing to do with my personal income tax.  This is not fiction, it is real money the company has to pay.

     

    And as owner of the (European)  company I think it is only fare that every company should comply to the same tax rules, and not avoiding the taxes like Apple did until now with the Double irish with Dutch Sandwich, because the current situation is unfair for other companies who have to pay the correct amount.

  • Reply 56 of 107
    Quote:

    Originally Posted by asdasd View Post

     

    The best thing the EU should do if it wants to survice 



    Yes, and of course just being there. The stickiness of having sunk capital and a workforce in a place. Apparently the workforce in Cork is about 50% non-Irish so it could theoretically go anywhere but the exodus in the EU is East West and South North not the other way around. Everybody thinks lower wages matter but not if you are attracting people from anywhere.

     

    Not that I would complain about Spain. I'd prefer Spain to Cork were I to apply for Apple.


    An entirely correct point of view, in my opinion ^^

     

    Quote:

    Originally Posted by asdasd View Post

     



    No there is a double taxation agreement, as there is for US corporations. The senate committee got that totally wrong. It can be argued that tax should be paid where IP is generated but that is not now international law. The Senate accused Apple of avoiding tax in the US by avoiding tax in Europe, in fact Apple owes more back tax to the US because of it's low tax payments in Ireland. This is what they mean by their "effective tax rate" on all conference calls. Its about 26% which indicates a desire to repatriate at some time.


    All in all, it's still big money!

     

    Quote:

    Originally Posted by cropr View Post

     

     

    I own a little software company and the company does pay a corporate tax on the profits it makes, which has nothing to do with my personal income tax.  This is not fiction, it is real money the company has to pay.

     

    And as owner of the (European)  company I think it is only fare that every company should comply to the same tax rules, and not avoiding the taxes like Apple did until now with the Double irish with Dutch Sandwich, because the current situation is unfair for other companies who have to pay the correct amount.


    Which means, that cannot afford that kind of "arrangement". It is a problem compounded by the fact that innovation comes from the smaller companies, and then trickles up through big companies capable of marketing it (or, in the case of Apple, of actually using it in a beautiful and efficient manner). Having the smaller companies paying maximum taxes reduces heavily the rate at which our society improves, at least from a technical perspective.

  • Reply 57 of 107
    ktappektappe Posts: 824member
    Quote:

    Originally Posted by anantksundaram View Post





    You're missing his point. The fact is, regardless of what you think, corporations do not pay taxes; you and I do. Almost all of it is passed though to us. Corporations are no more than a vehicle for tax collection.



    The government is bamboozling people into believing that there is some corprate entity that is separate from its tax-paying customers. That's pure fiction. You can choose to believe it if you wish.

     

    And you're not thinking this through. Your proposal applies to companies who use the WalMart model of high volume low margin and exclusively sell physical products. Tell me how banks who make most of their $ not from selling things but by margins an hedges should also not be taxed?

  • Reply 58 of 107
    cropr wrote: »
    I own a little software company and the company does pay a corporate tax on the profits it makes, which has nothing to do with my personal income tax.  This is not fiction, it is real money the company has to pay.

    And as owner of the (European)  company I think it is only fare that every company should comply to the same tax rules, and not avoiding the taxes like Apple did until now with the Double irish with Dutch Sandwich, because the current situation is unfair for other companies who have to pay the correct amount.

    This has nothing to do with "fairness", it has to do with insanely complex tax laws and how clever one must be to legally gain a competitive advantage. Apple has been above board on all of their tax dealings.
  • Reply 59 of 107
    Quote:
    Originally Posted by TheFly View Post

     

     

    Don't see anyone else follow up on this, so here goes.

     

    Apple pays taxes in every country where it sells products.  For example, Apple sells an iPhone in Germany, they pay tax on the profit to Germany.  The remaining profit is then sent off to Ireland for holding, since the Ireland didn't require taxes for corporations that we're registered in Ireland.

    ...

    You forget that Apple excessively reduces its profits for Apple Germany by IP costs imposed by Apple Ireland.

     

    Quote:
    Originally Posted by cropr View Post

     



    Apple is concentrating all its EU profits in Ireland (this is perfectly fine under the EU law), so it will pay 12,5% on the EU profit, and not on EU revenue, as corporate taxes are imposed on profits.


    There are rumors that Apple has a special agreement with Ireland that they have to pay less tax for profits made in Ireland (a rate of 2.5% has been indicated). And that agreement gets Ireland and Apple in the focus of the EU comission (as this advantage is not offered to all corporations in Ireland). The "Double Irish with a Dutch Sandwich" will possibly changed in the future, but Apple needs not to fear anything from that one.

  • Reply 60 of 107
    gatorguygatorguy Posts: 24,213member
    thefly wrote: »

    Apple pays taxes in every country where it sells products.  For example, Apple sells an iPhone in Germany, they pay tax on the profit to Germany.  The remaining profit is then sent off to Ireland for holding, since the Ireland didn't require taxes for corporations that we're registered in Ireland.

    Germany would be a poor example. By creative use of tax laws and special agreements with the Irish government Apple's German operations were able to show a loss, thus paying little to nothing in taxes for income derived from German citizens.
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