If there is a nickname for the tax loop hole called "Double Irish" then they probably did not name it just for Apple's sake. Likely lots of other companies used the same loophole. I suspect Apple and Ireland will win the appeal.
Indeed, other companies did take advantage of the “Double Irish” loophole. As the article mentions, however, Apple didn’t have to follow the “rules” of the Double Irish loophole the same way the other companies had to.
THAT is what might (might!) get them in trouble.
It's not just the "Double Irish" tax scheme that other companies also took advantage of just as you note. It's that Apple demanded, negotiated, and may have been granted a very special version of it, unique tax treatment not made available to any other company. That's what would get them in trouble, and what you might also have been alluding to.
But outside the court, no one yet knows if this is the end of the story or a new beginning. Well, perhaps Apple already knows.
Something never yet mentioned is that Apple has been allowed to take some money out of that escrow account to pay taxes in other jurisdictions. Not sure why, but it is. Perhaps there are taxes that courts ordered in other countries around the world, but the profits had already been funneled to their Irish subsidiaries?
You phrase it like Apple did something wrong. It's common for a large company to negotiate a special tax deal to locate in a particular place, even in the USA. These incentives can take various forms, such as:
Tax Breaks: Reduction or elimination of corporate taxes for a specified period.
Property Tax Abatements: Discounts or exemptions on property taxes to reduce operational costs.
Grants and Subsidies: Financial assistance or direct payments to support infrastructure, hiring, or expansion.
Job Creation Credits: Tax credits tied to the number of jobs the company promises to create.
Infrastructure Improvements: The local government may invest in roads, utilities, or other infrastructure upgrades to support the company’s needs.
Notable examples include Amazon's search for a second headquarters (HQ2), where cities across the USA offered huge incentives, or Tesla's gigafactories in various states where tax deals were central to the final location decision.
No, I feel it's possible Apple did something wrong, as do some legal experts. But you're phrasing it as it's not possible Apple did anything wrong?
This type of deal-making is not unique to Apple, nor to Ireland.
Isn't that what the entire ruling will hinge on?
and just to be clear, your opinion is it's not possible that Apple has done anything wrong, tax-wise, in this case?
Of course, anything is possible; Google could be a company that cares about its customers.
And IMO this is the reason Apple's event is on Monday. The EU announcement is Tuesday.
This makes little sense. Everyone can pretty much guess what Apple is going to announce: new iPhones, maybe an iPad or two, maybe a new Apple Watch, maybe some earbuds.
Plus Apple does this at 10am PDT. That's 7pm Central Europe time, after when most government/business decisions are made. There's no sense for EU regulators to wait until Apple's event is over (probably around 8:30pm their time), digest Apple's product announcements and factor these into some sort of decision to be announced on Tuesday (presumably before the West Coast has gotten to work).
As someone here mentioned in a previous discussion thread, most likely this is to get their product announcement out before the media goes into a frenzy concerning Tuesday's election debate.
The EU isn't waiting on Apple, it's the other way around with Apple avoiding their event for the same day as the EU decision. In the EU the date and decision was already set some time back. Sure the debate could have something to do with it as well, even if nothing Apple-y would be discussed unlike the EU tax case.
I remember less than two weeks ago Apple's event was said to be held Tuesday, but then changed to Monday with no mention why. The EU's announcement of the 10th to issue the tax case finding was within the past two weeks as well.
The debate has been official for a month, since Aug. 8th.
I'm connecting the dots.
Apple often makes product announcements on Tuesday (a hangover from the print press days) but those were speculative rumors.
In any case, I don't read much into Apple's timing about today's event. The only true inhibitor of a product announcement typically has to do with earnings so they don't get accused of manipulating stock prices.
We have also seen Apple avoid making announcements on September 11, probably because media attention is elsewhere.
Otherwise I'm not sure if there are enough dots to connect to form any sort of coherent explanation. We know that Apple doesn't like to play second fiddle to anyone. That's one of the major reasons they stopped attending tradeshows like Macworld Expo and CES.
We have collectively witnessed enough Apple product announcements over decades to know that the actual date of any given announcement has very little long term impact. Even moving the stock price 150 basis points for a day doesn't mean much in the long run.
Apple won't get graded whether Tim Cook had oatmeal or granola for breakfast on any given day.
I really like Apple, and I really hope they loose this court case. In my opinion taxes have to be payed where the money are earned, so the same rules for multinational corporations as for you and me!
If there is a nickname for the tax loop hole called "Double Irish" then they probably did not name it just for Apple's sake. Likely lots of other companies used the same loophole. I suspect Apple and Ireland will win the appeal.
Indeed, other companies did take advantage of the “Double Irish” loophole. As the article mentions, however, Apple didn’t have to follow the “rules” of the Double Irish loophole the same way the other companies had to.
THAT is what might (might!) get them in trouble.
It's not just the "Double Irish" tax scheme that other companies also took advantage of just as you note. It's that Apple demanded, negotiated, and may have been granted a very special version of it, unique tax treatment not made available to any other company. That's what would get them in trouble, and what you might also have been alluding to.
But outside the court, no one yet knows if this is the end of the story or a new beginning. Well, perhaps Apple already knows.
Something never yet mentioned is that Apple has been allowed to take some money out of that escrow account to pay taxes in other jurisdictions. Not sure why, but it is. Perhaps there are taxes that courts ordered in other countries around the world, but the profits had already been funneled to their Irish subsidiaries?
You phrase it like Apple did something wrong. It's common for a large company to negotiate a special tax deal to locate in a particular place, even in the USA. These incentives can take various forms, such as:
Tax Breaks: Reduction or elimination of corporate taxes for a specified period.
Property Tax Abatements: Discounts or exemptions on property taxes to reduce operational costs.
Grants and Subsidies: Financial assistance or direct payments to support infrastructure, hiring, or expansion.
Job Creation Credits: Tax credits tied to the number of jobs the company promises to create.
Infrastructure Improvements: The local government may invest in roads, utilities, or other infrastructure upgrades to support the company’s needs.
Notable examples include Amazon's search for a second headquarters (HQ2), where cities across the USA offered huge incentives, or Tesla's gigafactories in various states where tax deals were central to the final location decision.
No, I feel it's possible Apple did something wrong, as do some legal experts. But you're phrasing it as it's not possible Apple did anything wrong?
This type of deal-making is not unique to Apple, nor to Ireland.
Isn't that what the entire ruling will hinge on?
and just to be clear, your opinion is it's not possible that Apple has done anything wrong, tax-wise, in this case?
Of course, anything is possible; Google could be a company that cares about its customers.
We agree.
I corrected that as I suspected it was too subtle a dig
I have to say, even if Apple paid me, I'd find it soul-destroying to spend all day, every day, on a pro-Google blog waiting to chime in with anti-Google comments. You have fortitude; I'll give you that.
And IMO this is the reason Apple's event is on Monday. The EU announcement is Tuesday.
This makes little sense. Everyone can pretty much guess what Apple is going to announce: new iPhones, maybe an iPad or two, maybe a new Apple Watch, maybe some earbuds.
Plus Apple does this at 10am PDT. That's 7pm Central Europe time, after when most government/business decisions are made. There's no sense for EU regulators to wait until Apple's event is over (probably around 8:30pm their time), digest Apple's product announcements and factor these into some sort of decision to be announced on Tuesday (presumably before the West Coast has gotten to work).
As someone here mentioned in a previous discussion thread, most likely this is to get their product announcement out before the media goes into a frenzy concerning Tuesday's election debate.
The EU isn't waiting on Apple, it's the other way around with Apple avoiding their event for the same day as the EU decision. In the EU the date and decision was already set some time back. Sure the debate could have something to do with it as well, even if nothing Apple-y would be discussed unlike the EU tax case.
I remember less than two weeks ago Apple's event was said to be held Tuesday, but then changed to Monday with no mention why. The EU's announcement of the 10th to issue the tax case finding was within the past two weeks as well.
The debate has been official for a month, since Aug. 8th.
I'm connecting the dots.
Apple often makes product announcements on Tuesday (a hangover from the print press days) but those were speculative rumors.
In any case, I don't read much into Apple's timing about today's event. The only true inhibitor of a product announcement typically has to do with earnings so they don't get accused of manipulating stock prices.
We have also seen Apple avoid making announcements on September 11, probably because media attention is elsewhere.
Otherwise I'm not sure if there are enough dots to connect to form any sort of coherent explanation. We know that Apple doesn't like to play second fiddle to anyone. That's one of the major reasons they stopped attending tradeshows like Macworld Expo and CES.
We have collectively witnessed enough Apple product announcements over decades to know that the actual date of any given announcement has very little long term impact. Even moving the stock price 150 basis points for a day doesn't mean much in the long run.
Apple won't get graded whether Tim Cook had oatmeal or granola for breakfast on any given day.
You're not wrong. Apple's schedule is sometimes impacted by things happening outside their control, and without them publicly codifying it.
This case has dragged on forever! If the EU rules against Apple and Ireland, Apple might finally have to pay up the $14.5 billion it’s been holding in escrow. But, with all the back-and-forth legal stuff, it might be years before we see a final resolution.
This case has dragged on forever! If the EU rules against Apple and Ireland, Apple might finally have to pay up the $14.5 billion it’s been holding in escrow. But, with all the back-and-forth legal stuff, it might be years before we see a final resolution.
It is final now. There is nothing left to appeal. Done. Over. Not even days to see a final resolution.
Comments
In any case, I don't read much into Apple's timing about today's event. The only true inhibitor of a product announcement typically has to do with earnings so they don't get accused of manipulating stock prices.
We have also seen Apple avoid making announcements on September 11, probably because media attention is elsewhere.
Otherwise I'm not sure if there are enough dots to connect to form any sort of coherent explanation. We know that Apple doesn't like to play second fiddle to anyone. That's one of the major reasons they stopped attending tradeshows like Macworld Expo and CES.
We have collectively witnessed enough Apple product announcements over decades to know that the actual date of any given announcement has very little long term impact. Even moving the stock price 150 basis points for a day doesn't mean much in the long run.
Apple won't get graded whether Tim Cook had oatmeal or granola for breakfast on any given day.
I have to say, even if Apple paid me, I'd find it soul-destroying to spend all day, every day, on a pro-Google blog waiting to chime in with anti-Google comments. You have fortitude; I'll give you that.
But not the one that actually counts, apparently.
https://curia.europa.eu/juris/document/document.jsf?text=&docid=289923&pageIndex=0&doclang=EN&mode=req&dir=&occ=first&part=1&cid=883040
This is a major win for Vestager and EU. As EU can't charge taxes and the amount will go back to the member states.