Dáil debates

Wednesday, 7 September 2016

Government Appeal of European Commission Decision on State Aid to Apple: Motion

 

8:35 pm

Photo of Michael NoonanMichael Noonan (Limerick City, Fine Gael) | Oireachtas source

I have had no direct contact with the US Administration on the Apple case. I was in Washington some years ago when I met Mr. Jack Lew. Before that, I used to meet Mr. Tim Geithner frequently. However, general tax issues were under discussion then, not this case. My officials have had discussions with people in the US Treasury, for example, Mr. Bob Stack, who is fairly high up in the pecking order there. He has been in contact to discuss this matter, but I have not have any direct contact at either official or political level with the US Administration.

Clearly the Americans have a strong interest in this because the American political fear is that the US taxpayer will carry the ultimate liability. If Apple has to give €13 billion plus interest to the Irish Exchequer, Apple will look for a credit for the payment of that tax. It will present that credit to the Internal Revenue Service in the US to reduce its tax liability there. As the Deputy probably knows, it is not that international American companies do not have tax liabilities. Rather, their liabilities are not activated until they repatriate their profits. They have enormous profits that are outside the US. When they repatriate them, they are liable for tax. The tax rate is 35%. If one does the sums, the hit on the US Exchequer is much greater than €13 billion.

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