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 <img alt="1wink.gif" id="user_yui_3_7_3_1_1369243244393_1572" src="http://forums-files.appleinsider.com/images/smilies/1wink.gif" style="line-height:1.231;" name="user_yui_3_7_3_1_1369243244393_1572">
OK thanks. I must admit I was unaware every country in Europe Apple sells out if was a tax haven. I picked the UK at random. Anyone showing a pass through at no markup from Apple Ireland would suffice for now. By the way I personally wrote gazillions worth of checks (sorry cheques) to Apple UK over the years having owned and run several large dealerships. So I am doubly curious about this.
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.
I don't remember anyone claiming that. The main issue is income tax not sales tax. If you wanted to check up on their sales through Ireland, the details would be in their annual returns to one of their subsidiaries. Apple Sales International returns are here:
That must be to prevent Apple becoming domed. A surprising number of people get away with using the name Apple. Apple's ones appear to all be registered in Hollyhill so they'd be:
(none of those links work directly, just search for Apple and you can click through)
Levin said that ASI received $70b over the last few years and $30b of that given to AOI, which is a holdings company used to invest profits so not liable for anything other than income tax on the interest, which they pay at the US rate. Avoiding non-US income taxes would be done either by ASI or the subs that give them money. They said unapologetically that their overseas income tax rates are extremely low and paid just $900m despite their profits being higher than in the US.
This is where some of the senators were happy (Johnson mostly) because it means the possibility of taking profits from foreign countries and bringing them back to the US without paying the foreign governments the taxes on them. Apple just doesn't want to give the US government such a big chunk - they want to give them less than 10%.
Unless you're investor, then it's only curiosity. For the tax authorities, the only reason is so they can pick their pocket better.
That's a perjorative way of putting it. One might also say that the authorities would be better served by the transparency to regulate effectively and ensure appropriate tax is paid.
I don't remember anyone claiming that. The main issue is income tax not sales tax. If you wanted to check up on their sales through Ireland, the details would be in their annual returns to one of their subsidiaries. Apple Sales International returns are here:
That must be to prevent Apple becoming domed. A surprising number of people get away with using the name Apple. Apple's ones appear to all be registered in Hollyhill so they'd be:
Levin said that ASI received $70b over the last few years and $30b of that given to AOI, which is a holdings company used to invest profits so not liable for anything other than income tax on the interest, which they pay at the US rate. Avoiding non-US income taxes would be done either by ASI or the subs that give them money. They said unapologetically that their overseas income tax rates are extremely low and paid just $900m despite their profits being higher than in the US.
This is where some of the senators were happy (Johnson mostly) because it means the possibility of taking profits from foreign countries and bringing them back to the US without paying the foreign governments the taxes on them. Apple just doesn't want to give the US government such a big chunk - they want to give them less than 10%.
We are talking at cross purposes. LOL
For the record, I didn't mention 'sales tax'. I said tax on sales markup which is profit, i.e. income tax or that's what I meant to say at least. I am not trying to get into the nuanced discussion about tax in the US. I am specifically asking about the specific statement by Crowley that Apple sells products directly purchased in China through its Irish holding company, at zero mark up to all its European distribution centers thus eliminating income tax in all those countries on the sales of Apple products. I don't know how to be any more clear on what I am asking than this.
It's not hard to find plenty more articles from left-wing and right wing sources
Funny how none of those support your claims.
You said that AOI buys phones at cost from China and sells them to the US at just below retail.
1. Where's your evidence for that claim?
2. If that were true, how did Apple generate $20 B in income and $6 B in income taxes in the US?
3. And even if it were true, I'm still waiting for any evidence that Apple has done anything illegal.
For the record, I didn't mention 'sales tax'. I said tax on sales markup which is profit, i.e. income tax or that's what I meant to say at least. I am not trying to get into the nuanced discussion about tax in the US. I am specifically asking about the specific statement by Crowley that Apple sells products directly purchased in China through its Irish holding company, at zero mark up to all its European distribution centers thus eliminating income tax in all those countries on the sales of Apple products. I don't know how to be any more clear on what I am asking than this.
You are asking for a smoking gun that doesn't exist, it would be stupid of Apple to leave it laying around.
Apple have tied up all of their IP & accounting in all of the subsidiary companies that Marvin mentioned. There are also many others, Braeburn Capital (was in Reno), Baldwin Holdings (British Virgin Islands) & other 'Apple name' companies spring to mind in addition to iTunes S.à r.l (Luxembourg office that funnels all of iTunes purchases in Europe).
Baldwin Holdings appear to hold the coffers for Apple Operations International, which is one of the low tax entities that you want figures for, but the paper trail will lead you in circles.
You are asking for a smoking gun that doesn't exist, it would be stupid of Apple to leave it laying around.
Apple have tied up all of their IP & accounting in all of the subsidiary companies that Marvin mentioned. There are also many others, Braeburn Capital (was in Reno), Baldwin Holdings (British Virgin Islands) & other 'Apple name' companies spring to mind in addition to iTunes S.à r.l (Luxembourg office that funnels all of iTunes purchases in Europe).
Baldwin Holdings appear to hold the coffers for Apple Operations International, which is one of the low tax entities that you want figures for, but the paper trail will lead you in circles.
Actually I'm not asking for the smoking gun at all. Nor am I discussing the IP issue Marvin mentioned.
Crowley is stating the smoking gun you refer to (assuming you are indeed talking about what I am) exists I for one have a hard time believing what he states as fact is indeed fact. Having said that I have no idea so await some proof.
Crowley states, as fact, in plain English and in an authoritative and confident manner that Apple Ireland passes on all product to European distribution channels at retail thus making all Apple European distribution on paper a non profit set up and retaining all European sales profits in Ireland. At no times does Crowley indicate he is being speculative or just guessing.
I'm asking him to prove his assertion. If as you say it is impossible to trace then where exactly is Crowley's source?
I am specifically asking about the specific statement by Crowley that Apple sells products directly purchased in China through its Irish holding company, at zero mark up to all its European distribution centers thus eliminating income tax in all those countries on the sales of Apple products.
I see, I missed that statement. That explains how they have so little Corporation Tax. That is a pretty clever setup. One of the statements from the Harvard guy says:
"Apple avoids the reach of the foreign base company sales rules by contracting for manufacture of its products by third parties and in most cases, for U.S. tax purposes, selling to third parties. By using check-the-box disregarded entities, intercompany transactions within the group of companies that are classified as disregarded entities simply disappear."
The exhibit 1a memorandum has details of the whole setup on p17:
You said that AOI buys phones at cost from China and sells them to the US at just below retail.
He said sold to non-US subsidiaries. They probably wouldn't be allowed to sell them to the US as Apple Inc is subject to US tax law and all the Irish companies are subs of Apple Inc. That would be risky and they might not be able to hide transactions between the US and Ireland that way. It also allows them to focus attention on the US tax as a positive, Tim even said quite explicitly that they wanted them to look at the 30.5% US Income Tax rate and ignore the extremely low foreign tax rates.
I see, I missed that statement. That explains how they have so little Corporation Tax. That is a pretty clever setup. One of the statements from the Harvard guy says:
Partial quote only ...
I also said I don't believe what he said (I repeat again, as some ppl keep missing / ducking my point ... specifically the 'sale at no mark up from Ireland to European distribution channel') so unlike you I don't see it as a pretty clever set up ... I'd like some proof before accepting what seems like guesswork at best to me.
You said that AOI buys phones at cost from China and sells them to the US at just below retail.
1. Where's your evidence for that claim?
2. If that were true, how did Apple generate $20 B in income and $6 B in income taxes in the US?
3. And even if it were true, I'm still waiting for any evidence that Apple has done anything illegal.
I'm really getting tired of saying this to you. This is not about the US. I have not mentioned the US in any of these posts about Apple's dealings in Ireland. The income that Apple earns in the US and the corporation (not income) taxe that they pay in the US are as far as I've seen, fine, I have no quibbles with them, though I haven't looked particularly closely because the US situation isn't of much interest to me.
And I've never said that Apple have done anything illegal. I've said the exact opposite many times.
Please stop trying to call me on things I haven't said. I'm not going to repeat this again, as it's getting tiresome.
On a different note, I do need to make one correction, I said that it was AOI that handles the purchasing from China and reselling in Europe, but it's actually ASI. A simple mistake.
I'm really getting tired of saying this to you. This is not about the US. I have not mentioned the US in any of these posts about Apple's dealings in Ireland. The income that Apple earns in the US and the corporation (not income) taxe that they pay in the US are as far as I've seen, fine, I have no quibbles with them, though I haven't looked particularly closely because the US situation isn't of much interest to me.
And I've never said that Apple have done anything illegal. I've said the exact opposite many times.
Please stop trying to call me on things I haven't said. I'm not going to repeat this again, as it's getting tiresome.
On a different note, I do need to make one correction, I said that it was AOI that handles the purchasing from China and reselling in Europe, but it's actually ASI. A simple mistake.
OK this time I agree with you. I too keep having folks here try to side track your points I try to refer to as being tied up with the US. I am 100% focussed on your statements regarding Apple's financial model in Europe. I would love to know if you are guessing or know for a fact Apple Ireland ships at retail (almost) to all the European distributors and retains all profits in Ireland. I know it isn't illegal but it would make what Tim said yesterday disingenuous to me at least. I really don't want to believe it is true hence wanting proof.
Update: Thank you for your source.
Regarding the article by Walter Hickey ... I already see a 'word of mouth exaggeration' at work here. Hickey wrote "and resells them at a major markup to other Apple affiliates in Europe", you re worded that to read that Apple moved product to distributors at almost retail. I quote "Apple Operations International then sells those iPhones to Apple UK, Apple Germany, Apple France etc for close to the retail price.". (You corrected yourself that you meant all products).
I am sorry but that is disingenuous too. There is plenty of room for a sizable (and perfectly normal) difference in those two versions of the truth. Your version is, to put it politely, 'spun'.
Actually I'm not asking for the smoking gun at all. Nor am I discussing the IP issue Marvin mentioned.
Crowley is stating the smoking gun you refer to (assuming you are indeed talking about what I am) exists I for one have a hard time believing what he states as fact is indeed fact. Having said that I have no idea so await some proof.
Crowley states, as fact, in plain English and in an authoritative and confident manner that Apple Ireland passes on all product to European distribution channels at retail thus making all Apple European distribution on paper a non profit set up and retaining all European sales profits in Ireland. At no times does Crowley indicate he is being speculative or just guessing.
I'm asking him to prove his assertion. If as you say it is impossible to trace then where exactly is Crowley's source?
That's not strictly what I said. Apple's operations in Europe do make some profit that they pay corporation tax on, I imagine it would be impossible to tune the machine so finely that they come out completely even, considering that they do have operational costs and retail premises and staff costs to cover. Simply the Double Irish trick that Apple has pulled allows it to move the major part of the value of their sellable products into Apple Irish bank accounts, via subsidiaries.
There is no "smoking gun" here, it's not a detective novel, but its plain to see that this is what's happening - the revenue and taxes for ASI are pretty stark evidence of a dodge; $38b in profit since 2009, $21m in tax over the same period, an effective rate of 0.06%. And they have no employees.
In Apple's own words:
"ASI is an operating company with employees who manage the procurement and supply chain for Apple products sold abroad by ADI. Accordingly, ASI files an Irish corporate tax return and pays taxes in Ireland."
But they have no actual employees registered in Ireland.
And for the avoidance of doubt, this is not illegal, and this is not a problem with Apple, this is a problem with the tax systems that allow it.
I'm really getting tired of saying this to you. This is not about the US. I have not mentioned the US in any of these posts about Apple's dealings in Ireland. The income that Apple earns in the US and the corporation (not income) taxe that they pay in the US are as far as I've seen, fine, I have no quibbles with them, though I haven't looked particularly closely because the US situation isn't of much interest to me.
And I've never said that Apple have done anything illegal. I've said the exact opposite many times.
Please stop trying to call me on things I haven't said. I'm not going to repeat this again, as it's getting tiresome.
On a different note, I do need to make one correction, I said that it was AOI that handles the purchasing from China and reselling in Europe, but it's actually ASI. A simple mistake.
What you said is that AOI buys phones at low cost in China and then sells them to Apple US at close to retail pricing (or ASI - whichever fantasy you're having right now). That is blatantly wrong and is pretty strong evidence that you don't have any idea what you're talking about in this entire subject.
Furthermore, you continue to accuse Apple of wrongdoing yet have never provided one shred of evidence to back your position.
What you said is that AOI buys phones at low cost in China and then sells them to Apple US at close to retail pricing (or ASI - whichever fantasy you're having right now). That is blatantly wrong and is pretty strong evidence that you don't have any idea what you're talking about in this entire subject.
I have never said that. I never said that ASI (or AOI for that matter) sold anything to Apple US for sale in the US. You've repeated that many times and its simply not true, I never said it. I challenge you to find a single instance of me saying that.
Giving you the benefit of the doubt that the "US" was a slip, and replacing it with "UK" for arguments sake (which I have said). Even so, why is it wrong? It's a good business tactic. I think Apple are very clever for doing it. It's what ASI was set up to do if you read Apple's own description of the company. How and why am I "blatantly" wrong?
Quote:
Originally Posted by jragosta
Furthermore, you continue to accuse Apple of wrongdoing yet have never provided one shred of evidence to back your position.
That's a lie. Over the course of these discussions about Apple's tax I don't think I have once accused Apple of doing anything wrong. You keep saying that I've done so, but have yet to provide a shred of evidence that I've done so.
EDIT: I realise I said I wouldn't repeat this again just a few posts ago. I guess that makes me a liar in one respect. I definitely won't repeat it again, I'll just point back to this post.
That's not strictly what I said. Apple's operations in Europe do make some profit that they pay corporation tax on, I imagine it would be impossible to tune the machine so finely that they come out completely even, considering that they do have operational costs and retail premises and staff costs to cover. Simply the Double Irish trick that Apple has pulled allows it to move the major part of the value of their sellable products into Apple Irish bank accounts, via subsidiaries.
There is no "smoking gun" here, it's not a detective novel, but its plain to see that this is what's happening - the revenue and taxes for ASI are pretty stark evidence of a dodge; $38b in profit since 2009, $21m in tax over the same period, an effective rate of 0.06%. And they have no employees.
In Apple's own words:
"<span style="line-height:1.231;">ASI is an operating company with employees who manage the procurement and supply chain for Apple products sold abroad by ADI. Accordingly, ASI files an Irish corporate tax return and pays taxes in Ireland."</span>
<span style="line-height:1.231;">But they have no actual employees registered in Ireland.</span>
<span style="line-height:1.231;">And for the avoidance of doubt, this is not illegal, and this is not a problem with Apple, this is a problem with the tax systems that allow it.</span>
I think baring your exaggeration noted in my last post, we agree. As an Apple retailer my company was given a 33% discount off of retail to resell, a nice healthy margin on which substantial taxes were paid. That was buying directly from Apple. Let us assume Apple Centers owned by Apple work on similar basis (and I agree perhaps lower as they don't need as much with Apple supporting them in so many ways). That would still leave Apple Ireland with a large percentage of retail value on products as retained income (not profit obviously). Nothing underhand nothing abnormal nothing that wasn't happening in 1979 though the mid 1990's that I can attest to. I believe the margins went lower after that but the basic premiss that Apple has always retained a large portion of profits at central locations is unchanged I am sure. It is simply good business. If Ireland offered tax incentives (as they did) to attract business good for them and good for Apple. As a large share holder I applaud this ... and I assure you my politics are independent / centrist.
Comments
OK thanks. I must admit I was unaware every country in Europe Apple sells out if was a tax haven. I picked the UK at random. Anyone showing a pass through at no markup from Apple Ireland would suffice for now. By the way I personally wrote gazillions worth of checks (sorry cheques) to Apple UK over the years having owned and run several large dealerships. So I am doubly curious about this.
Quote:
Originally Posted by Crowley
Apple Inc doesn't do any country-by-country reporting to my knowledge. It would be very helpful if they did.
Helpful for whom?
I don't remember anyone claiming that. The main issue is income tax not sales tax. If you wanted to check up on their sales through Ireland, the details would be in their annual returns to one of their subsidiaries. Apple Sales International returns are here:
http://www.cro.ie/search/ListSubDocs.aspx?id=157192&type=C
There's a company called Apple Dome Management:
http://www.cro.ie/search/CompanyDetails.aspx?id=336784&type=C
That must be to prevent Apple becoming domed. A surprising number of people get away with using the name Apple. Apple's ones appear to all be registered in Hollyhill so they'd be:
Apple Distribution International:
http://www.cro.ie/search/CompanyDetails.aspx?id=470672&type=C
Apple operations:
http://www.cro.ie/search/CompanyDetails.aspx?id=492405&type=C
Apple Operations Europe:
http://www.cro.ie/search/CompanyDetails.aspx?id=76927&type=C
Apple Operations International:
http://www.cro.ie/search/CompanyDetails.aspx?id=76941&type=C
Apple Retail Holding Europe:
http://www.cro.ie/search/CompanyDetails.aspx?id=379311&type=C
Apple Sales Ireland:
http://www.cro.ie/search/CompanyDetails.aspx?id=86705&type=C
Apple Sales International:
http://www.cro.ie/search/CompanyDetails.aspx?id=157192&type=C
(none of those links work directly, just search for Apple and you can click through)
Levin said that ASI received $70b over the last few years and $30b of that given to AOI, which is a holdings company used to invest profits so not liable for anything other than income tax on the interest, which they pay at the US rate. Avoiding non-US income taxes would be done either by ASI or the subs that give them money. They said unapologetically that their overseas income tax rates are extremely low and paid just $900m despite their profits being higher than in the US.
This is where some of the senators were happy (Johnson mostly) because it means the possibility of taking profits from foreign countries and bringing them back to the US without paying the foreign governments the taxes on them. Apple just doesn't want to give the US government such a big chunk - they want to give them less than 10%.
Quote:
Originally Posted by Crowley
Me, so I can answer the question. Tax authorities too no doubt.
Unless you're investor, then it's only curiosity. For the tax authorities, the only reason is so they can pick their pocket better.
We are talking at cross purposes. LOL
For the record, I didn't mention 'sales tax'. I said tax on sales markup which is profit, i.e. income tax or that's what I meant to say at least. I am not trying to get into the nuanced discussion about tax in the US. I am specifically asking about the specific statement by Crowley that Apple sells products directly purchased in China through its Irish holding company, at zero mark up to all its European distribution centers thus eliminating income tax in all those countries on the sales of Apple products. I don't know how to be any more clear on what I am asking than this.
Quote:
Originally Posted by Crowley
One might also say that the authorities would be better served by the transparency to regulate effectively and ensure appropriate tax is paid.
One might. If one were wishing to be kind to the government. All this assuming we can define things like "regulate effectively" and "appropriate tax".
Funny how none of those support your claims.
You said that AOI buys phones at cost from China and sells them to the US at just below retail.
1. Where's your evidence for that claim?
2. If that were true, how did Apple generate $20 B in income and $6 B in income taxes in the US?
3. And even if it were true, I'm still waiting for any evidence that Apple has done anything illegal.
Quote:
Originally Posted by digitalclips
We are talking at cross purposes. LOL
For the record, I didn't mention 'sales tax'. I said tax on sales markup which is profit, i.e. income tax or that's what I meant to say at least. I am not trying to get into the nuanced discussion about tax in the US. I am specifically asking about the specific statement by Crowley that Apple sells products directly purchased in China through its Irish holding company, at zero mark up to all its European distribution centers thus eliminating income tax in all those countries on the sales of Apple products. I don't know how to be any more clear on what I am asking than this.
You are asking for a smoking gun that doesn't exist, it would be stupid of Apple to leave it laying around.
Apple have tied up all of their IP & accounting in all of the subsidiary companies that Marvin mentioned. There are also many others, Braeburn Capital (was in Reno), Baldwin Holdings (British Virgin Islands) & other 'Apple name' companies spring to mind in addition to iTunes S.à r.l (Luxembourg office that funnels all of iTunes purchases in Europe).
Baldwin Holdings appear to hold the coffers for Apple Operations International, which is one of the low tax entities that you want figures for, but the paper trail will lead you in circles.
Actually I'm not asking for the smoking gun at all. Nor am I discussing the IP issue Marvin mentioned.
Crowley is stating the smoking gun you refer to (assuming you are indeed talking about what I am) exists I for one have a hard time believing what he states as fact is indeed fact. Having said that I have no idea so await some proof.
Crowley states, as fact, in plain English and in an authoritative and confident manner that Apple Ireland passes on all product to European distribution channels at retail thus making all Apple European distribution on paper a non profit set up and retaining all European sales profits in Ireland. At no times does Crowley indicate he is being speculative or just guessing.
I'm asking him to prove his assertion. If as you say it is impossible to trace then where exactly is Crowley's source?
I see, I missed that statement. That explains how they have so little Corporation Tax. That is a pretty clever setup. One of the statements from the Harvard guy says:
"Apple avoids the reach of the foreign base company sales rules by contracting for manufacture of its products by third parties and in most cases, for U.S. tax purposes, selling to third parties. By using check-the-box disregarded entities, intercompany transactions within the group of companies that are classified as disregarded entities simply disappear."
The exhibit 1a memorandum has details of the whole setup on p17:
http://www.hsgac.senate.gov/download/?id=CDE3652B-DA4E-4EE1-B841-AEAD48177DC4
He said sold to non-US subsidiaries. They probably wouldn't be allowed to sell them to the US as Apple Inc is subject to US tax law and all the Irish companies are subs of Apple Inc. That would be risky and they might not be able to hide transactions between the US and Ireland that way. It also allows them to focus attention on the US tax as a positive, Tim even said quite explicitly that they wanted them to look at the 30.5% US Income Tax rate and ignore the extremely low foreign tax rates.
Partial quote only ...
I also said I don't believe what he said (I repeat again, as some ppl keep missing / ducking my point ... specifically the 'sale at no mark up from Ireland to European distribution channel') so unlike you I don't see it as a pretty clever set up ... I'd like some proof before accepting what seems like guesswork at best to me.
Quote:
Originally Posted by jragosta
Funny how none of those support your claims.
You said that AOI buys phones at cost from China and sells them to the US at just below retail.
1. Where's your evidence for that claim?
2. If that were true, how did Apple generate $20 B in income and $6 B in income taxes in the US?
3. And even if it were true, I'm still waiting for any evidence that Apple has done anything illegal.
I'm really getting tired of saying this to you. This is not about the US. I have not mentioned the US in any of these posts about Apple's dealings in Ireland. The income that Apple earns in the US and the corporation (not income) taxe that they pay in the US are as far as I've seen, fine, I have no quibbles with them, though I haven't looked particularly closely because the US situation isn't of much interest to me.
And I've never said that Apple have done anything illegal. I've said the exact opposite many times.
Please stop trying to call me on things I haven't said. I'm not going to repeat this again, as it's getting tiresome.
On a different note, I do need to make one correction, I said that it was AOI that handles the purchasing from China and reselling in Europe, but it's actually ASI. A simple mistake.
And as I posted earlier, Business Insider summarise this arrangement here: http://www.businessinsider.com/how-apple-reduces-what-it-pays-in-taxes-2013-5 from information available taken from the Senate report and from Apple's own filings.
OK this time I agree with you. I too keep having folks here try to side track your points I try to refer to as being tied up with the US. I am 100% focussed on your statements regarding Apple's financial model in Europe. I would love to know if you are guessing or know for a fact Apple Ireland ships at retail (almost) to all the European distributors and retains all profits in Ireland. I know it isn't illegal but it would make what Tim said yesterday disingenuous to me at least. I really don't want to believe it is true hence wanting proof.
Update: Thank you for your source.
Regarding the article by Walter Hickey ... I already see a 'word of mouth exaggeration' at work here. Hickey wrote "and resells them at a major markup to other Apple affiliates in Europe", you re worded that to read that Apple moved product to distributors at almost retail. I quote "Apple Operations International then sells those iPhones to Apple UK, Apple Germany, Apple France etc for close to the retail price.". (You corrected yourself that you meant all products).
I am sorry but that is disingenuous too. There is plenty of room for a sizable (and perfectly normal) difference in those two versions of the truth. Your version is, to put it politely, 'spun'.
Quote:
Originally Posted by digitalclips
Actually I'm not asking for the smoking gun at all. Nor am I discussing the IP issue Marvin mentioned.
Crowley is stating the smoking gun you refer to (assuming you are indeed talking about what I am) exists I for one have a hard time believing what he states as fact is indeed fact. Having said that I have no idea so await some proof.
Crowley states, as fact, in plain English and in an authoritative and confident manner that Apple Ireland passes on all product to European distribution channels at retail thus making all Apple European distribution on paper a non profit set up and retaining all European sales profits in Ireland. At no times does Crowley indicate he is being speculative or just guessing.
I'm asking him to prove his assertion. If as you say it is impossible to trace then where exactly is Crowley's source?
That's not strictly what I said. Apple's operations in Europe do make some profit that they pay corporation tax on, I imagine it would be impossible to tune the machine so finely that they come out completely even, considering that they do have operational costs and retail premises and staff costs to cover. Simply the Double Irish trick that Apple has pulled allows it to move the major part of the value of their sellable products into Apple Irish bank accounts, via subsidiaries.
There is no "smoking gun" here, it's not a detective novel, but its plain to see that this is what's happening - the revenue and taxes for ASI are pretty stark evidence of a dodge; $38b in profit since 2009, $21m in tax over the same period, an effective rate of 0.06%. And they have no employees.
In Apple's own words:
"ASI is an operating company with employees who manage the procurement and supply chain for Apple products sold abroad by ADI. Accordingly, ASI files an Irish corporate tax return and pays taxes in Ireland."
But they have no actual employees registered in Ireland.
And for the avoidance of doubt, this is not illegal, and this is not a problem with Apple, this is a problem with the tax systems that allow it.
What you said is that AOI buys phones at low cost in China and then sells them to Apple US at close to retail pricing (or ASI - whichever fantasy you're having right now). That is blatantly wrong and is pretty strong evidence that you don't have any idea what you're talking about in this entire subject.
Furthermore, you continue to accuse Apple of wrongdoing yet have never provided one shred of evidence to back your position.
Quote:
Originally Posted by jragosta
What you said is that AOI buys phones at low cost in China and then sells them to Apple US at close to retail pricing (or ASI - whichever fantasy you're having right now). That is blatantly wrong and is pretty strong evidence that you don't have any idea what you're talking about in this entire subject.
I have never said that. I never said that ASI (or AOI for that matter) sold anything to Apple US for sale in the US. You've repeated that many times and its simply not true, I never said it. I challenge you to find a single instance of me saying that.
Giving you the benefit of the doubt that the "US" was a slip, and replacing it with "UK" for arguments sake (which I have said). Even so, why is it wrong? It's a good business tactic. I think Apple are very clever for doing it. It's what ASI was set up to do if you read Apple's own description of the company. How and why am I "blatantly" wrong?
Quote:
Originally Posted by jragosta
Furthermore, you continue to accuse Apple of wrongdoing yet have never provided one shred of evidence to back your position.
That's a lie. Over the course of these discussions about Apple's tax I don't think I have once accused Apple of doing anything wrong. You keep saying that I've done so, but have yet to provide a shred of evidence that I've done so.
EDIT: I realise I said I wouldn't repeat this again just a few posts ago. I guess that makes me a liar in one respect. I definitely won't repeat it again, I'll just point back to this post.
I think baring your exaggeration noted in my last post, we agree. As an Apple retailer my company was given a 33% discount off of retail to resell, a nice healthy margin on which substantial taxes were paid. That was buying directly from Apple. Let us assume Apple Centers owned by Apple work on similar basis (and I agree perhaps lower as they don't need as much with Apple supporting them in so many ways). That would still leave Apple Ireland with a large percentage of retail value on products as retained income (not profit obviously). Nothing underhand nothing abnormal nothing that wasn't happening in 1979 though the mid 1990's that I can attest to. I believe the margins went lower after that but the basic premiss that Apple has always retained a large portion of profits at central locations is unchanged I am sure. It is simply good business. If Ireland offered tax incentives (as they did) to attract business good for them and good for Apple. As a large share holder I applaud this ... and I assure you my politics are independent / centrist.
Quote:
Originally Posted by Marvin
There's a company called Apple Dome Management:
http://www.cro.ie/search/CompanyDetails.aspx?id=336784&type=C
That must be to prevent Apple becoming domed.