EU to examine role Revenue ‘opinions’ in Apple’s tax status

EU to examine role Revenue ‘opinions’ in Apple’s tax status: "The European Commission’s inquiry into Apple’s arrangements in Ireland centres on two tax “opinions” handed down by the Revenue in 1991 and 2007, it has emerged.
Outgoing competition commissioner Joaquin Almunia will set out the basis for the investigation in the EU Official Journal on Monday, opening a 30-day window for interested parties to respond. In question is whether the tax arrangements conferred illegal state-aid to Apple. The Government has always argued the inquiry is groundless, saying it will vigorously contest all elements of the complaint.
It is understood Apple will contest that the complaint is “baseless” and “profoundly wrong” in respect of Irish-based subsidiaries Apple Operations Europe (AOE) and Apple Sales International.
It is further understood that Apple will argue that Revenue always adopted an appropriately “aggressive” stance in its engagements with the company.
Heavily criticised
Apple, which has had an Irish operation since 1980, was heavily criticised last year after a subcommittee of the US Senate heard it was paying a 2 per cent corporate tax rate in Ireland. The company’s position is that this was an unfair description of its business, that it pays an effective 20 per cent tax rate globally and has been paying the statutory tax rate on the profit made by AOE."



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