Irish finance minister decries EU's demand for $15B+ in Apple back taxes, says it's not Ir...

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In a German interview this week, Ireland's finance minister attacked the European Commission's ruling calling for the collection of $15 billion in back taxes (plus interest) from Apple, saying it was both unjustified and outside Ireland's responsibility.




"We are not the global tax collector for everybody else," Paschal Donohoe remarked to Frankfurter Allgemeine, quoted by Reuters. He also reiterated the Irish government's main defense, claiming that the tax breaks extended to Apple were available to other companies as well, and broke neither Irish nor European Union laws. Under E.U. regulations, extending favors to some companies but not others can constitute illegal state aid.

Despite its protests, the Irish government is supposedly finalizing an arrangement to collect up to $17.7 billion from Apple and hold it in escrow, pending an appeal with the Commission. The government was originally required to collect the money by Jan. 3, but has been slow to respond, despite a Commission warning in May that it could be brought to court.

In August 2016 the Commission ruled that Ireland had extended "illegal tax benefits" to Apple, which it said were also "reverse engineered" to keep them low. Even though the company was funneling large sums of international revenue through its Irish subsidiaries, it's alleged to have paid 1 percent in taxes in 2003, and as little as 0.005 percent by 2014. Apple has repeatedly insisted that it follows the law in every country it operates in.

The Irish government has a strong incentive to keep Apple happy, since apart from the risk of losing what taxes it is paid, the company's European headquarters are located in Cork and a long-delayed data center may eventually be built near Athenry.
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Comments

  • Reply 1 of 31
    Perhaps the EU should be careful in placing an ideological lever on Ireland.

    😬
  • Reply 2 of 31
    steven n.steven n. Posts: 1,108member
    Here we go again.
  • Reply 3 of 31
    SpamSandwichSpamSandwich Posts: 30,848member
    Hard to believe the fighting Irish are allowing themselves to be cowed and bullied by the EU.
    entropys
  • Reply 4 of 31
    YvLyYvLy Posts: 75member
    The fighting Irish lost their fists long time ago ...
  • Reply 5 of 31
    SpamSandwichSpamSandwich Posts: 30,848member
    YvLy said:
    The fighting Irish lost their fists long time ago ...
    Evidently. What a shame.
  • Reply 6 of 31
    YvLy said:
    The fighting Irish lost their fists long time ago ...
    Yep, not unlike a similarly named college football team in the US....
  • Reply 7 of 31
    Does anybody have any insight into how much of Apple's foreign cash is liable for payment of taxes (eventually) in the U.S. as opposed to other countries? One would think it would be a relatively easy matter for Apple to determine how much of its product and services are sold in a particular country and how much in tax is due to that country and to pay those taxes promptly. Has this Irish-EU standoff arisen because U.S. tax law allows Apple to hold pre-tax earnings offshore and re-patriate it at a time of its choice? So, maybe the EU sees an opportunity here to grab taxes on a big chunk of Apple's pre-tax earnings that should rightly be taxed by the U.S.? If so, one would think there should be some pressure on the U.S. to amend its tax laws to prevent companies like Apple from indefinitely holding pre-tax earnings overseas for some kind of temporary tax holiday. Taxes should be paid on an annual basis, regardless of where the pre-tax cash is parked. If I tried to hold some of my pre-tax income offshore to avoid the current year's taxes and tell the government I want to pick the year in which to pay taxes in, I think I'd be risking jail time.
  • Reply 8 of 31
    gsrennie said:
    One would think it would be a relatively easy matter for Apple to determine how much of its product and services are sold in a particular country and how much in tax is due to that country ...
    What does selling in a country have to do with the taxes you pay there? For example, say I made iPhones in the US -- i.e., incurred almost all of the direct and indirect costs here -- and I made my living exporting them to France. What is the tax I should pay in France? (Or you can turn that around, and think of the example of a bottle of champagne you buy in the US -- the retailer selling it to you in the US should certainly pay taxes on his pre-tax store profits from that sale, but are you saying that the French champagne maker should pay taxes in the US as well? Why?).
  • Reply 9 of 31
    e1618978e1618978 Posts: 6,074member
    Maybe the UK would give them Northern Ireland in exchange for them leaving the EU at the same time that the UK does - that way BrExit and IrExit could negotiate trade deals as a team.
  • Reply 10 of 31
    boltsfan17boltsfan17 Posts: 2,158member
    gsrennie said:
    Does anybody have any insight into how much of Apple's foreign cash is liable for payment of taxes (eventually) in the U.S. as opposed to other countries? One would think it would be a relatively easy matter for Apple to determine how much of its product and services are sold in a particular country and how much in tax is due to that country and to pay those taxes promptly. Has this Irish-EU standoff arisen because U.S. tax law allows Apple to hold pre-tax earnings offshore and re-patriate it at a time of its choice? So, maybe the EU sees an opportunity here to grab taxes on a big chunk of Apple's pre-tax earnings that should rightly be taxed by the U.S.? If so, one would think there should be some pressure on the U.S. to amend its tax laws to prevent companies like Apple from indefinitely holding pre-tax earnings overseas for some kind of temporary tax holiday. Taxes should be paid on an annual basis, regardless of where the pre-tax cash is parked. If I tried to hold some of my pre-tax income offshore to avoid the current year's taxes and tell the government I want to pick the year in which to pay taxes in, I think I'd be risking jail time.
    None of Apple's overseas cash horde is liable for tax payements in the U.S. since the money is earned overseas. Apple already pays taxes here in the U.S. for all the profit it books in the U.S. There is no tax repatriation right now. Last time was 2004 I belive. If Apple were to bring back any amount of money held overseas back into the U.S., they would get taxed 35%. The EU standoff came about because the EU feels Ireland has basically given Apple illegal state aid for alleged tax agreeements. It has nothing to do with taxes in the U.S. Not sure if you are confused at how this whole offshore thing works for large coprorations. Apple isn't moving income earned in the U.S. overseas. If you are taking income earned in the U.S. and then hiding it offshore to avoid paying taxes, that's obviously against the law. Thats not what Apple is doing. The way Apple is set up, they are booking profits overseas so they don't have to pay taxes here, which is perfectly legal.
     
    edited August 2017 avon b7
  • Reply 11 of 31
    carnegiecarnegie Posts: 667member
    gsrennie said:
    Does anybody have any insight into how much of Apple's foreign cash is liable for payment of taxes (eventually) in the U.S. as opposed to other countries? One would think it would be a relatively easy matter for Apple to determine how much of its product and services are sold in a particular country and how much in tax is due to that country and to pay those taxes promptly. Has this Irish-EU standoff arisen because U.S. tax law allows Apple to hold pre-tax earnings offshore and re-patriate it at a time of its choice? So, maybe the EU sees an opportunity here to grab taxes on a big chunk of Apple's pre-tax earnings that should rightly be taxed by the U.S.? If so, one would think there should be some pressure on the U.S. to amend its tax laws to prevent companies like Apple from indefinitely holding pre-tax earnings overseas for some kind of temporary tax holiday. Taxes should be paid on an annual basis, regardless of where the pre-tax cash is parked. If I tried to hold some of my pre-tax income offshore to avoid the current year's taxes and tell the government I want to pick the year in which to pay taxes in, I think I'd be risking jail time.
    Taxes would be due in the U.S. on meaningfully all of Apple's as-yet unremitted foreign earnings if those earnings were remitted to the parent company - around $250 billion worth.

    This dispute isn't about other nations claiming that they are owed taxes based on sales of Apple products in those nations. For the most part, advanced economies (i.e. the governments of nations with advanced economies) don't require that income taxes be paid on profits just because those profits derive from sales which occurred in those nations. Generally speaking, international income tax accounting practices are based on where value is considered to be created, not where it is realized.

    The dispute here is how much income tax should be owed to Ireland (based, in large part, on profits which derive from sales made in other nations).

    And just to be clear, the reason Apple (and other companies) can defer paying U.S. income taxes on the kinds of earnings we're talking about is that they are foreign earnings. They aren't U.S. earnings shifted offshore to avoid U.S. income taxation. Most advanced economies don't tax those kinds of foreign earnings at all anymore - immediately or on a deferred basis. Many nations have already gotten rid of their extraterritorial taxation policies, the U.S. has not yet.

    That said... you, as an individual, could do the same thing that Apple does in deferring paying U.S. income taxes on certain kinds of foreign earnings if those earnings aren't distributed to you from foreign corporations which you own (or own portions of).
  • Reply 12 of 31
    gatorguygatorguy Posts: 20,288member
    gsrennie said:
    Does anybody have any insight into how much of Apple's foreign cash is liable for payment of taxes (eventually) in the U.S. as opposed to other countries? One would think it would be a relatively easy matter for Apple to determine how much of its product and services are sold in a particular country and how much in tax is due to that country and to pay those taxes promptly. Has this Irish-EU standoff arisen because U.S. tax law allows Apple to hold pre-tax earnings offshore and re-patriate it at a time of its choice? So, maybe the EU sees an opportunity here to grab taxes on a big chunk of Apple's pre-tax earnings that should rightly be taxed by the U.S.? If so, one would think there should be some pressure on the U.S. to amend its tax laws to prevent companies like Apple from indefinitely holding pre-tax earnings overseas for some kind of temporary tax holiday. Taxes should be paid on an annual basis, regardless of where the pre-tax cash is parked. If I tried to hold some of my pre-tax income offshore to avoid the current year's taxes and tell the government I want to pick the year in which to pay taxes in, I think I'd be risking jail time.
    None of Apple's overseas cash horde is liable for tax payements in the U.S. since the money is earned overseas. Apple already pays taxes here in the U.S. for all the income it makes in the U.S. There is no tax repatriation right now. Last time was 2004 I belive. If Apple were to bring back any amount of money held overseas back into the U.S., they would get taxed 35%. The EU standoff came about because the EU feels Ireland has basically given Apple illegal state aid for alleged tax agreeements. It has nothing to do with taxes in the U.S. Not sure if you are confused at how this whole offshore thing works for large coprorations. Apple isn't moving income earned in the U.S. overseas. If you are taking income earned in the U.S. and then hiding it offshore to avoid paying taxes, that's obviously against the law. Thats not what Apple is doing. The way Apple is set up, the majority of their income is earned overseas so they aren't required to pay taxes on that in the U.S.
     
    You are correct, altho Apple rather than transferring cash out of the US is transferring the intellectual property rights behind the iPhone, developed in the US for the most part, to its Irish Apple International subsidiary.

    That's what enables Apple to claim that Apple Stores in Germany, and Apple in France, and Apple in a dozen+ other countries make little to no profits, even claiming losses at times if I remember correctly and avoiding corporate taxes on sales made in those countries. It's the Irish subsidiary that technically owns and sells the product to various Apple retail outlets at relatively high prices to pay for the intellectual property rights they own and thus takes the lions-share of profits from those sales.

     Some counties of course have caught on finally, with Apple having been found to be evading (not avoiding) taxes in Japan and ponying up after a tax fraud investigation of Apple in Italy. Not sure what the status of the Australian tax inquiry is. Until very recently (and I don't believe the change has actually gone into effect yet) the Irish subsidiary who controls most of Apple's profits was not taxable in any country on the earth, answering to no taxing authority. That's why profits from countries far removed from Europe like Japan and Australia were moved via Singapore to Apple Ireland accounts. Tricky stuff.

    And yes other companies like Google and IBM and Pfizer and hundreds of other big and profitable multinationals have their own tax avoidance schemes that have been found to stray into illegal tax evasion or tax fraud in some cases. That doesn't make it right because others do it. 
    edited August 2017
  • Reply 13 of 31
    gatorguy said:

    ... altho Apple rather than transferring cash out of the US is transferring the intellectual property rights behind the iPhone, developed in the US for the most part, to its Irish Apple International subsidiary.
    Can you provide a good cite -- i.e., one that convinced you -- for this? Thanks.
    edited August 2017
  • Reply 14 of 31
    gsrennie said:
    Does anybody have any insight into how much of Apple's foreign cash is liable for payment of taxes (eventually) in the U.S. as opposed to other countries? One would think it would be a relatively easy matter for Apple to determine how much of its product and services are sold in a particular country and how much in tax is due to that country and to pay those taxes promptly. Has this Irish-EU standoff arisen because U.S. tax law allows Apple to hold pre-tax earnings offshore and re-patriate it at a time of its choice? So, maybe the EU sees an opportunity here to grab taxes on a big chunk of Apple's pre-tax earnings that should rightly be taxed by the U.S.? If so, one would think there should be some pressure on the U.S. to amend its tax laws to prevent companies like Apple from indefinitely holding pre-tax earnings overseas for some kind of temporary tax holiday. Taxes should be paid on an annual basis, regardless of where the pre-tax cash is parked. If I tried to hold some of my pre-tax income offshore to avoid the current year's taxes and tell the government I want to pick the year in which to pay taxes in, I think I'd be risking jail time.
    None of Apple's overseas cash horde is liable for tax payements in the U.S. since the money is earned overseas. Apple already pays taxes here in the U.S. for all the profit it books in the U.S. There is no tax repatriation right now. Last time was 2004 I belive. If Apple were to bring back any amount of money held overseas back into the U.S., they would get taxed 35%. The EU standoff came about because the EU feels Ireland has basically given Apple illegal state aid for alleged tax agreeements. It has nothing to do with taxes in the U.S. Not sure if you are confused at how this whole offshore thing works for large coprorations. Apple isn't moving income earned in the U.S. overseas. If you are taking income earned in the U.S. and then hiding it offshore to avoid paying taxes, that's obviously against the law. Thats not what Apple is doing. The way Apple is set up, they are booking profits overseas so they don't have to pay taxes here, which is perfectly legal.
     
    It is a little more complicated than just an Ireland-EU spat. The US is also quite involved.

    Given that the US imposes worldwide taxation upon repatriation, there are many billions potentially owed to the US Treasury should that money be ever brought back to the US by Apple. Ireland claims that all of the taxes owed to it have been paid, so nothing more is needed, owed, or wanted there. EU says no, Ireland should collect more: they used the argument that since Ireland is a net recipient of EU aid, the additional taxes that Ireland collects from companies like Apple would lower the amount of aid that EU has to provide to Ireland from its coffers.

    The US view is: "hey, you're now getting your paws on the money that could/would be, under current law, owed to our treasury." So, even if the EU wins this case, that is only stage 1 of a longer process. The US (most certainly, the Trump administration) will come down on them like a ton of bricks, and it will end up back in the courts somewhere. Stage 2 will be all about where that court fight will take place. Stage 3 will be the court fight between EU and the US. Then there'll be appeals. And Stage N -- assuming the EU finally wins the case against Apple -- will be when the EU starts to go after every major US multinational with operations in Ireland. Rinse and repeat.
    edited August 2017
  • Reply 15 of 31
    gatorguygatorguy Posts: 20,288member
    gatorguy said:

    ... altho Apple rather than transferring cash out of the US is transferring the intellectual property rights behind the iPhone, developed in the US for the most part, to its Irish Apple International subsidiary.
    Can you provide a good cite -- i.e., one that convinced you -- for this? Thanks.
    You already know it to be fact so I assume you're asking to benefit others that don't read as much? Pretty sure you followed the US Senate investigation a few years back (2012 I think) to determine how Apple and other multinationals avoid corporate taxation.  

    Apple's own documents submitted under Subpoena  spoke about it. Pull up the Senate report if you missed reading it. It includes links and/or references to the pertinent documents. There's other references here if you're curious about what the Irish themselves discovered, along with a report on the Japanese tax evasion case enabled in part by that transferred IP. 

    https://asia.nikkei.com/Politics-Economy/Policy-Politics/Japan-casts-wider-net-for-corporate-tax-evaders
    https://www.irishtimes.com/business/financial-services/intellectual-property-rights-at-the-core-of-apple-s-irish-subsidiaries-1.1401739

    I realized you might reply to say you don't have time to look for the Senate report (!) and other readers might not even know where to start, so here's that link too.
    https://www.gpo.gov/fdsys/pkg/CHRG-113shrg81657/pdf/CHRG-113shrg81657.pdf
    edited August 2017
  • Reply 16 of 31
    carnegiecarnegie Posts: 667member
    gatorguy said:

    ... altho Apple rather than transferring cash out of the US is transferring the intellectual property rights behind the iPhone, developed in the US for the most part, to its Irish Apple International subsidiary.
    Can you provide a good cite -- i.e., one that convinced you -- for this? Thanks.
    Nearly 40 years ago Apple (parent) entered into an agreement with Irish subsidiaries to share R&D costs. Pursuant to that agreement (as updated since), the Irish subsidiaries have rights to distribute Apple products in areas of the world outside of the Americas.

    You can see, e.g., (former) CFO Peter Oppenheimer's testimony before the U.S. Senate in 2013.
  • Reply 17 of 31
    gatorguygatorguy Posts: 20,288member
    carnegie said:
    gatorguy said:

    ... altho Apple rather than transferring cash out of the US is transferring the intellectual property rights behind the iPhone, developed in the US for the most part, to its Irish Apple International subsidiary.
    Can you provide a good cite -- i.e., one that convinced you -- for this? Thanks.
    Nearly 40 years ago Apple (parent) entered into an agreement with Irish subsidiaries to share R&D costs. Pursuant to that agreement (as updated since), the Irish subsidiaries have rights to distribute Apple products in areas of the world outside of the Americas.

    You can see, e.g., (former) CFO Peter Oppenheimer's testimony before the U.S. Senate in 2013.
    Thanks, that's a more direct link to the pertinent section of the Senate Report I linked in my previous post. 
    edited August 2017
  • Reply 18 of 31
    entropysentropys Posts: 1,622member
    gsrennie said:
    One would think it would be a relatively easy matter for Apple to determine how much of its product and services are sold in a particular country and how much in tax is due to that country ...
    What does selling in a country have to do with the taxes you pay there? For example, say I made iPhones in the US -- i.e., incurred almost all of the direct and indirect costs here -- and I made my living exporting them to France. What is the tax I should pay in France? (Or you can turn that around, and think of the example of a bottle of champagne you buy in the US -- the retailer selling it to you in the US should certainly pay taxes on his pre-tax store profits from that sale, but are you saying that the French champagne maker should pay taxes in the US as well? Why?).
    Because you can never have enough Other Peoples' Money.
    SpamSandwichavon b7
  • Reply 19 of 31
    carnegie said:
    gatorguy said:

    ... altho Apple rather than transferring cash out of the US is transferring the intellectual property rights behind the iPhone, developed in the US for the most part, to its Irish Apple International subsidiary.
    Can you provide a good cite -- i.e., one that convinced you -- for this? Thanks.
    Nearly 40 years ago Apple (parent) entered into an agreement with Irish subsidiaries to share R&D costs. Pursuant to that agreement (as updated since), the Irish subsidiaries have rights to distribute Apple products in areas of the world outside of the Americas.

    You can see, e.g., (former) CFO Peter Oppenheimer's testimony before the U.S. Senate in 2013.
    ======
    WARNING!!!! SOMEWHAT LONG. (I HAVE HIGHLIGHTED THE KEY POINTS THAT APPLE MAKES IN BOLD. BUT I AM CITING MOST OF OPPENHEIMER'S TESTIMONY SINCE I DON'T WISH TO BE ACCUSED OF PULLING THINGS OUT OF CONTEXT).
    ======

    TESTIMONY OF PETER OPPENHEIMER, SENIOR VICE PRESIDENT AND CHIEF FINANCIAL OFFICER, APPLE INC., CUPERTINO, CALIFORNIA

    Mr. OPPENHEIMER. Good morning, Chairman Levin, Ranking Member McCain, Members of this Subcommittee. My name is Peter Oppenheimer, and I am Apple’s chief financial officer. I would like to discuss the structure and management of Apple’s global business and financial operations.

    In the United States our operational structure is quite simple: We sell to our customers through our retail stores, online stores, and channel partners. We provide our award-winning support to our customers through the Genius Bar and AppleCare. We pay taxes to Federal, State, and local governments on the full profits from these sales.

    Outside the United States we seek to provide the same industry-leading products, services, and support that our U.S. customers have come to expect. We now sell the iPhone and iPad in over 100 countries.

    Like all multinational companies, Apple must follow the local laws and regulations in each region where we operate. This often requires Apple to establish a physical presence not only in the region but also in the particular country where we wish to sell our products and services.

    Apple’s presence in these countries often takes the form of Apple-owned subsidiaries. These in-country subsidiaries acquire products to sell in their markets through Apple-owned regional operating subsidiaries, which in turn acquire products from our contract manufacturers.

    In the European region, our primary operating subsidiaries are incorporated in Ireland. These subsidiaries, which were established in the early 1980s, now employ nearly 4,000 people in Ireland, and we recently broke ground on an expansion to our campus in Cork.

    Since 1980, Apple has had an R&D cost-sharing agreement with our Irish subsidiaries. The agreement was first put in place when Apple was about 5 years old and wanted to sell its computers overseas. At that time, Apple’s revenues were one-tenth of 1 percent of what they are today, and the invention of the iPhone was decades away.

    Today the substance of the agreement is largely unchanged except for our expansion into more countries and recent updates to comply with new U.S. Treasury regulations. Our cost-sharing agreement, which is common in the industry, is audited by the IRS, and we are in full compliance with all laws and regulations.

    The agreement enables Apple to share the costs and risks of developing new products with our Irish subsidiaries. Virtually all of this R&D, and the jobs that go with it, take place in the United States. In exchange for this funding, the Irish subsidiaries have rights to distribute in Europe and Asia products created by the R&D funded by the agreement.

    We have used this method to distribute our products internationally for more than 30 years. More than half of our ongoing R&D costs are funded by Apple Ireland. When times are good, as they have been in recent years, our Irish subsidiaries benefit greatly, as we do in the United States. When Apple lost money in the mid-1990s, our Irish subsidiaries lost money as well. I mention losing money in the 1990s because it serves as a reminder of how close Apple came to going out of business.

    In 1997, we were on the brink of bankruptcy and about out of cash. In just 2 years, we lost $2 billion. I can tell you firsthand we were facing the very real possibility of a world without Apple.

    A big part of the turnaround was a company-wide effort to streamline and simplify so Apple could survive. We restructured our operations and finances to make everything as simple and effi- cient as possible.

    As part of that effort, we consolidated our European post-tax in- come into two existing subsidiaries: a holding company, Apple Operations International, or AOI; and an operating company, Apple Sales International, or ASI.

    The consolidation eliminated enormous complexity in handling foreign bank accounts and improved our ability to manage currency risk. While AOI and ASI are both incorporated in Ireland, neither is tax resident there under the rules of Irish law. Indeed, Irish law contemplates that companies may be incorporated in Ireland with- out being tax resident there. 

    ======

    So: (i) Apple has had this arrangement in place for 30 years; it started when they were small, and they've kept it the same since they're large -- in other words, it's not something that they started to do just because they became the most profitable company on earth. (ii) More than half the R&D costs are funded by Apple Ireland, even though most of the R&D is done in the US; (iii) The Irish subsidiary has, over the 30 years, shared in profits and they've shared in losses; (iv) over 60% of Apple's sales are abroad.

    What exactly is at issue here? That Apple has not terminated this arrangement just because they've become larger and more successful? What is the logic for why they should do that? (@gatorguy, please feel free to explain why as well).

    edited August 2017
  • Reply 20 of 31
    gatorguygatorguy Posts: 20,288member
    carnegie said:
    gatorguy said:

    ... altho Apple rather than transferring cash out of the US is transferring the intellectual property rights behind the iPhone, developed in the US for the most part, to its Irish Apple International subsidiary.
    Can you provide a good cite -- i.e., one that convinced you -- for this? Thanks.
    Nearly 40 years ago Apple (parent) entered into an agreement with Irish subsidiaries to share R&D costs. Pursuant to that agreement (as updated since), the Irish subsidiaries have rights to distribute Apple products in areas of the world outside of the Americas.

    You can see, e.g., (former) CFO Peter Oppenheimer's testimony before the U.S. Senate in 2013.

    So: (i) Apple has had this arrangement in place for 30 years; it started when they were small, and they've kept it the same since they're large -- in other words, it's not something that they started to do just because they became the most profitable company on earth. (ii) More than half the R&D costs are funded by Apple Ireland, even though most of the R&D is done in the US; (iii) The Irish subsidiary has, over the 30 years, shared in profits and they've shared in losses; (iv) over 60% of Apple's sales are abroad.

    What exactly is at issue here? That Apple has not terminated this arrangement just because they've become larger and more successful? What is the logic for why they should do that? (@gatorguy, please feel free to explain why as well).

    Seems you're using a Red Herring as no one here in this thread is saying Apple should terminate the sharing agreement. You asked for evidence of its existence indicating some doubt on your part that Apple was yet another company to make it part of their tax strategies. Since you now have the proof you asked for has it become something you feel a need to argue in support of?

    Yes other companies use transfer agreements too in efforts to avoid taxation with various levels of success depending on how aggressively they wield it. Apple is not the only big multinational using these types of transfer agreements and found to evade taxes or prompt fraud investigations in some countries when used inappropriately, and won't be the last I'm sure. Google too, along with Amazon and Facebook and other rich American companies are all dealing with tax investigations of their own. 

    As for the EU Commission IANAL and have no firm law-based opinion either way whether they will be successful. The only thing that's clear to me is that far too many very wealthy companies are getting ever richer and more powerful by shifting tax obligations off their shoulders and onto "others", modern-day versions of the old Railroad, Cattle and Oil Baron's.
    edited August 2017
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