Affiliate Disclosure
If you buy through our links, we may get a commission. Read our ethics policy.

Apple's Ireland subsidiary paid Apple US $24.8 billion for 2021

View from Apple's latest Cork offices. Image Credit: CorkBeo

New filings from Apple's Irish head office show that the company's European operations earned $211.1 billion in revenue, of which it paid out $24.8 billion to its US parent.

Apple's counts as one of Ireland's biggest companies, because it funnels income from the company's subsidiaries across Europe. Traditionally, it has done so in order to benefit from Ireland's low tax rate, although that is now changing.

It's also advantageous for Apple to leave money overseas that it has earned from outside the US, rather than repatriating all of it. Consequently, despite an increase in revenue of 42.4% from $148.2 billion in 2020, to $211.1 billion in 2021, little of it has been sent back to Apple US.

Instead, according to the Irish Examiner, the Irish subsidiary has paid its US parent company $24.8 billion for the same period.

The accounts for a financial year ending September 25, 2021, show that Apple has provided for an income tax bill of $11.6 billion. Some $8.5 billion of that is listed as being for corporation tax, but the filings do not break down further into how much is to be paid in Ireland or the US.

Despite the more than 40% rise in revenue, the accounts show that profits fell from $70.3 billion in 2020, to $26 billion in 2021.

The accounts also show that the number of employees at Apple's subsidiaries that report to the Irish division, has rise from 51,255, to 52, 563. More than 6,000 of those work directly for Apple's Ireland operations, which recently added new offices at Horgan's Quay in Cork.



9 Comments

🍪
aderutter 17 Years · 625 comments

Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…

🍪
gatorguy 13 Years · 24634 comments

aderutter said:
Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…

The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203

🍪
Stabitha_Christie 3 Years · 582 comments

gatorguy said:
aderutter said:
Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203

Apple said it would repatriate the cash over five years which would wrap up some time next year. I have no idea what the source AI has that says this isn't happening. Keeping in form they have failed to provide a citation. 

🎅
crowley 15 Years · 10431 comments

gatorguy said:
aderutter said:
Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…
The buybacks can't use un-repatriated funds. That's why you see Apple issuing bonds to at least partially fund the buybacks. That money held overseas, and as I understand it not necessarily subject to Irish or even EU law (see Paradise Papers), is significantly shielded from taxation by any authority including the US and Ireland. 

So much for that vaunted repatiation of $200B held overseas that Apple implied would have happened in 2018 or shortly thereafter. It did not. 

EDIT: A bit more detailed article concerning the Irish story reported by AppleInsider:
https://www.irishtimes.com/business/technology/apple-s-irish-subsidiary-doubles-pretax-profits-to-64bn-1.4871203
Apple said it would repatriate the cash over five years which would wrap up some time next year. I have no idea what the source AI has that says this isn't happening. Keeping in form they have failed to provide a citation. 

I'm not sure why AI are saying little of Apple Ireland's revenue is being sent back to the parent as a dividend at all, since it is evidently profit that they will send back.  $24.8 billion repatriated of $26 billion profit looks pretty comprehensive to me, since Apple will presumably be investing some money in European operations.

I can't see that the Irish Examiner article that is the source for AI says anything similar, AI have added it in.  Weird.

carnegie 10 Years · 1082 comments

aderutter said:
Does anyone know if the stock buy-backs are undetaken in US or overseas? Might it make sense for non-US income to be used for buy-backs to avoid repatriation tax? Just pondering an area I don’t know too much about…

Stock buybacks (of AAPL) are done by the parent company - the main U.S. Apple corporation. But it doesn't really matter anymore (i.e. since the TCJA of 2017 went into effect), for U.S. income tax purposes, whether foreign earnings are actually repatriated. Prior not-yet repatriated earnings were deemed repatriated by the TCJA, and the new minimum taxes on new foreign earnings that the TCJA created apply whether the earnings in question are repatriated or not. So Apple has to pay applicable U.S. income taxes on its foreign earnings - past or current - whether it repatriates foreign earnings or not.