EU-imposed Apple Irish tax bill could exceed $21.2B if appeal process fails

"Depending on all the claims that might emerge from the US or other EU countries at the instigation or prompting of Commissioner Vestager, [the tax edict] could be at that figure at max," the head of Ireland's Revenue's International Division Eamonn O'Dea told RTE Radio. "But who knows what is going to transpire over the coming years?"

O'Dea has been opposed a large European Commission tax ruling all along. During the course of the investigation, he claimed that the Irish tax authority had collected the full amount that Apple owed the nation, but perhaps not all that was owed to other European countries.

"If the two Apple companies concerned had been resident in Ireland of course there would be a basis for having charged the amounts mentioned or alleged by the Commission," reiterated O'Dea. "While somebody may be owed 13 billion euro, Ireland isn't owed it."

"We have applied the law fully in Revenue. It should not be put at Ireland's door." - head of Ireland's Revenue's International Division Eamonn O'Dea

Apple employs over 6,000 people in Cork, Ireland, and has been established in the country since 1980. Apple has said that it will remain in Ireland regardless of the results of the European Commission's investigation and ruling.

"I do not think Ireland should be trying to tax 60 percent of the global profits of this particular multinational corporation based on their branch in Cork.," said O'Dea. "We have applied the law fully in Revenue. It should not be put at Ireland's door or Revenue's door."

The European Commission's investigation on Apple's tax arrangement with Ireland concluded on Tuesday, with the ruling mandating Apple to pay 13 billion euro ($14.5 billion) to Ireland in back taxes, reduced only if other E.U. countries seek part of the proceedings. The regulatory group claimed that tax rates on European profits were illegally low at 0.005 percent in 2014, and 1 percent in 2003, and the payment was based on increasing that effective tax to 12.5 percent.

Apple will appeal the edict. Some Irish governmental officials have commenced discussions on how to fight the ruling.

A FAQ posted on Tuesday lays out Apple's path to an appeal, and notes that the process will take several years to wrap up.