Six of Apple's Irish entities will now be required to make certain financial information publicly available, thanks to the company shifting to "limited" status.
Apple has often been accused of exploiting loopholes in low-tax countries to avoid paying in the markets where it makes most of its money. In Europe, for instance, it has funneled much of its income through Irish subsidiaries.
Apple's operations in Ireland have been under scrutiny for some time. In 2016, the European Commission ruled that Ireland extended illegal state aid to Apple, allowing the multi-billion dollar company to skimp on the amount of taxes owed on its operations.
In May of 2019, Apple ranked as Ireland's biggest company, raking in nearly $134 billion in sales. Much of the profit had come from overseas, but Ireland's tax law allowed much of the money to filter through special tax breaks, reducing what the company would owe.
In September 2019, Apple had made arguments against the idea that Ireland was core to its central planning. The European Union General Court had required Apple to pay $14.4 billion in back taxes to Ireland, even though that country negotiated its tax rate with the company and is in court supporting Apple.
Much of this had been caused by Apple's "unlimited" status in Ireland, according to The Irish Times. By holding "unlimited" status, the company did not have to file publicly-available accounts, which hid the fact that some arms were paying effective tax rates of less than one percent.
Apple has changed the status of six of its Irish branches to "limited," which will require them to file full annual reports. The reports will detail sales, profits, tax bills, and what cash they've got in Ireland.
The branches affected are Apple Operations Europe, Apple Sales Ireland, Apple Sales International, Apple Distribution International, Apple Operations, and Apple Data Services Ireland.
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This has been planned for since October of 2014 FWIW. That's why Apple should have no real issue with the new reporting requirements in revised Irish tax law slated to go in effect this year. They've had seven years to craft "a multijurisdictional project involving the British Virgin Islands (BVI), Cayman, Guernsey, Isle of Man and Jersey" to shield revenue from taxes.
None of the big companies, and our massively profitable US techs are the poster children, are going to be completely forthright on their finances unless they have no other option, and in the foreseeable future there are options.
To flesh out Gatorguy's post:
https://www.icij.org/investigations/paradise-papers/apples-secret-offshore-island-hop-revealed-by-paradise-papers-leak-icij/