Apple's Ireland subsidiary paid Apple US $24.8 billion for 2021

Posted:
in General Discussion
New filings from Apple's Irish head office show that the company's European operations earned $211.1 billion in revenue, of which it paid out $24.8 billion to its US parent.

View from Apple's latest Cork offices. Image Credit: CorkBeo
View from Apple's latest Cork offices. Image Credit: CorkBeo


Apple's counts as one of Ireland's biggest companies, because it funnels income from the company's subsidiaries across Europe. Traditionally, it has done so in order to benefit from Ireland's low tax rate, although that is now changing.

It's also advantageous for Apple to leave money overseas that it has earned from outside the US, rather than repatriating all of it. Consequently, despite an increase in revenue of 42.4% from $148.2 billion in 2020, to $211.1 billion in 2021, little of it has been sent back to Apple US.

Instead, according to the Irish Examiner, the Irish subsidiary has paid its US parent company $24.8 billion for the same period.

The accounts for a financial year ending September 25, 2021, show that Apple has provided for an income tax bill of $11.6 billion. Some $8.5 billion of that is listed as being for corporation tax, but the filings do not break down further into how much is to be paid in Ireland or the US.

Despite the more than 40% rise in revenue, the accounts show that profits fell from $70.3 billion in 2020, to $26 billion in 2021.

The accounts also show that the number of employees at Apple's subsidiaries that report to the Irish division, has rise from 51,255, to 52, 563. More than 6,000 of those work directly for Apple's Ireland operations, which recently added new offices at Horgan's Quay in Cork.

Read on AppleInsider

Comments

  • Reply 1 of 9
    aderutteraderutter Posts: 621member
    Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
  • Reply 2 of 9
    gatorguygatorguy Posts: 24,584member
    aderutter said:
    Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
    The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

    So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

    EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
    https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203
    edited May 2022 ctt_zhMacsWithPenguinssphericmuthuk_vanalingam
  • Reply 3 of 9
    gatorguy said:
    aderutter said:
    Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
    The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

    So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

    EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
    https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203
    Apple said it would repatriate the cash over five years which would wrap up some time next year. I have no idea what the source AI has that says this isn't happening. Keeping in form they have failed to provide a citation. 
    MacsWithPenguins
  • Reply 4 of 9
    crowleycrowley Posts: 10,453member
    gatorguy said:
    aderutter said:
    Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
    The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

    So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

    EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
    https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203
    Apple said it would repatriate the cash over five years which would wrap up some time next year. I have no idea what the source AI has that says this isn't happening. Keeping in form they have failed to provide a citation. 
    I'm not sure why AI are saying little of Apple Ireland's revenue is being sent back to the parent as a dividend at all, since it is evidently profit that they will send back.  $24.8 billion repatriated of $26 billion profit looks pretty comprehensive to me, since Apple will presumably be investing some money in European operations.

    I can't see that the Irish Examiner article that is the source for AI says anything similar, AI have added it in.  Weird.
    MacsWithPenguins
  • Reply 5 of 9
    carnegiecarnegie Posts: 1,082member
    aderutter said:
    Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
    Stock buybacks (of AAPL) are done by the parent company - the main U.S. Apple corporation. But it doesn't really matter anymore (i.e. since the TCJA of 2017 went into effect), for U.S. income tax purposes, whether foreign earnings are actually repatriated. Prior not-yet repatriated earnings were deemed repatriated by the TCJA, and the new minimum taxes on new foreign earnings that the TCJA created apply whether the earnings in question are repatriated or not. So Apple has to pay applicable U.S. income taxes on its foreign earnings - past or current - whether it repatriates foreign earnings or not.
    muthuk_vanalingam
  • Reply 6 of 9
    carnegiecarnegie Posts: 1,082member
    gatorguy said:
    aderutter said:
    Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
    The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

    So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

    EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
    https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203
    That was one of the reasons why, in years past, Apple issued debt to help fund buybacks. But it isn't an issue now. Apple owes U.S. income taxes on its foreign earnings - past and current - whether it actually repatriates those earnings or not. So, even if a controlled foreign corporation retains some of its earnings, Apple (i.e. the U.S. parent) has to pay the applicable U.S. income taxes on those earnings.

    That said, according to reporting (from, e.g., the Irish Examiner) Apple has actually repatriated the bulk of its previously not-yet repatriated foreign earnings. It reportedly repatriated nearly $300 billion worth in 2019 and 2020. I haven't read the Irish B1C's myself, but I don't have reason to think the reporting by the Irish Examiner (and others) is wrong.

    As for reasons why Apple still issues debt, there are other reasons why it makes sense. For one, even if you're trying to get close to a zero net cash position, having a pile of cash that's largely offset by a pile of debt gives you more flexibility - and more ability to deal with unanticipated developments - than having neither. That's especially the case considering how most of Apple's debt is structured. And the effective cost to Apple of having debt, rather then having less debt and less cash, is very small. It can borrow money at low rates which aren't that much higher than what it's able to safely earn on its retained cash.
    muthuk_vanalingam
  • Reply 7 of 9
    carnegiecarnegie Posts: 1,082member
    gatorguy said:
    aderutter said:
    Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
    The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

    So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

    EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
    https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203
    Apple said it would repatriate the cash over five years which would wrap up some time next year. I have no idea what the source AI has that says this isn't happening. Keeping in form they have failed to provide a citation. 
    Apple is paying the U.S. income taxes it owes on past foreign earnings, as a consequence of the TCJA, over a period of years - extending, I believe, beyond 2023.

    But it has, reportedly, already repatriated the bulk of its previously not-yet repatriated foreign earnings.
  • Reply 8 of 9
    carnegiecarnegie Posts: 1,082member
    crowley said:
    gatorguy said:
    aderutter said:
    Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
    The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

    So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

    EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
    https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203
    Apple said it would repatriate the cash over five years which would wrap up some time next year. I have no idea what the source AI has that says this isn't happening. Keeping in form they have failed to provide a citation. 
    I'm not sure why AI are saying little of Apple Ireland's revenue is being sent back to the parent as a dividend at all, since it is evidently profit that they will send back.  $24.8 billion repatriated of $26 billion profit looks pretty comprehensive to me, since Apple will presumably be investing some money in European operations.

    I can't see that the Irish Examiner article that is the source for AI says anything similar, AI have added it in.  Weird.
    Yeah, I think the OP got some things wrong. It doesn't really matter for U.S. income tax purposes whether Apple repatriates its foreign earnings and it seems Apple has actually already repatriated the bulk of them.

    Its foreign subsidiaries don't repatriate the bulk of their revenues, of course. They can't really do that. A lot of expenses and costs have to come out of those revenues first. But they have been repatriating the bulk of their earnings.
  • Reply 9 of 9
    anantksundaramanantksundaram Posts: 20,407member
    The profit margin implied by this is not at all out of line with Apple's margins elsewhere, including in the US.
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