This is a first. Brussels had never hit as hard against the tax practices of multinational, ie the first in the world in terms of market capitalization (513 billion) and cash (207 billion euros). Condemning Apple to pay more than € 13 billion to Ireland, the European Commission imposed Tuesday the biggest tax adjustment in its history. A colossal sum that has nothing of a fine the company the richest in the world will just have to pay back to the Irish Republic “tax benefits” preferential and abusive – plus interest – the latter has made him from 1991. … An illegal practice under the EU rules, since distort free competition in the heart of the single European market. “The selective tax treatment Apple in Ireland is illegal under EU rules on state aid, writes the Commission in support of its decision, because it gives the company a significant advantage over other companies that are subject to the same national tax rules. “ We could not be more clear, unlike the assembly of Apple, whose formidable complexity was perfectly clarified after three years of investigation
See no employees or premises
Margrethe Vestager, the dreaded Commissioner of Competition portfolio -. it Google also has in his sights with three indictments – finalized the decision summarized in a 130-page document. The former Danish Minister of Finance, who have inspired the figure of Birgitte Nyborg in the series Borgen, the sums in some damning figures for Apple. It indicates that “the tax treatment Apple” in Ireland helped him through two rescripts (agreements) tax, “to be applying an effective tax rate on corporate 1% of its profits in 2003, rates decreased to 0.005% in 2014 “. either, according to his calculations, about 50 euros tax paid in Ireland for every million profit located in Ireland where the firm directly employs 5500 people.
the EU executive goes further by stressing that in reality, Apple has avoided “tax on virtually all the profits generated through the sale of Apple products throughout the EU’s single market ‘ by recording all sales in Ireland rather than in countries where its products were purchased. However, the two subsidiaries in Ireland Apple (Apple Operations Europe and Apple Sales International), which hold the intellectual property rights to use the group outside of North America, have hardly paid d taxes between 1991 and 2007 in the country (2% on average over these sixteen years.) Almost all their profits were assigned to a “seat” located outside of Ireland. A “seat” without domiciliation, which had no employees, had no premises and whose benefits were actually taxed “nowhere”, dissects the Commission. In other words, while Ireland already shows the tax rate on the lowest societies of Europe, at 12.5%, its administration has reserved an ultra-privileged tax regime – and long secret – the manufacturer of iPhone, endorsing the fact that unrealized profits in Ireland pass through the country before evaporating in nature. In exchange, Apple has continued and intensified its development in Ireland over the years, particularly in Cork city, where thousands of jobs have been created.
Margrethe Vestager, which has become the most combative of Commissioners of the EU executive had already sanctioned last year Starbucks (the Netherlands) and Fiat (Luxembourg), amounting to 30 million euros each for identical practices or tax ruling tax ruling. And the giant Amazon online commerce is also in the sights of Brussels, for a rescript in Luxembourg. But the money is in the case of Apple’s 40 times larger and sprays the recovery inflicted on EDF for using illegal French state in the amount of 1.4 billion euros.
since the tax optimization schemes introduced by Apple on the Continent have also resulted in a loss of tax revenue for other Member States of the Union, the EU executive explained that the amount Apple will have to return to the Irish tax authorities could be downgraded. Everything will depend on the amounts that other countries litigation with Apple claiming the US tech giant.
Apple, but also Ireland, immediately said they would make unprecedented appeal the decision . “Apple respects the law and pay all taxes due wherever he is now,” said the Californian group, for which “The case raised by the Commission does not apply to amounts paid by Apple in taxes, but the way the government collects money. ” Its CEO, Tim Cook, said that the company “had become the largest taxpayer in Ireland, the largest taxpayer in the United States and the largest taxpayer in the world.” And Apple to warn Brussels on the very negative signal to extra-large multinationals. “The decision, concludes the group is set to unveil the iPhone in early September 7 in San Francisco, will have a profound and damaging effect on investment and the creation in Europe.”
Benefits housed Bermuda
Meanwhile, Ireland, which ought to benefit from a record flow of money to public finances and recently reformed the most controversial aspects of its tax system, disputes the fact that preferential treatment has been granted. “I strongly disagree with the Commission’s decision,” said the Irish Finance Minister, Michael Noonan, who intends to defend “integrity” of the tax system . “It is important, he says, to send the message that Ireland remains an attractive destination as a stable for significant investment.”
the US Treasury and the White House, denouncing for months Brussels fury against the American groups have also sided with Apple, saying the move could threaten foreign investment in Europe. They challenge the retroactivity of this decision and accused Brussels of usurping his powers by setting up as “supranational fiscal authority”. A activism that challenges in their international cooperation established under ‘OECD auspices to end the aggressive tax planning for multinationals. An attitude to say the least contradictory, contradicting the war waged by the US tax authorities to repatriate billions of dollars in profits Apple housed abroad, particularly in Bermuda and that Washington would be able to tax it. As if the imposition of Apple was primarily the coffers of the US state. The art of using double standards
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