Pearse Doherty (Donegal South West, Sinn Fein) | Oireachtas source

Apple Operations International, AOI, is incorporated here and is not tax resident in Bermuda, the Cayman Islands or any other country. The company does not have tax residency here but is incorporated in Ireland and controlled in the United States. Either the United States decides the company is tax resident in the US because it is controlled there or Ireland decides the company is tax resident in Ireland because it is incorporated here. AOI does not have to go through the Dutch sandwich of Bermuda because it does not have tax residency anywhere. That is the point and we facilitate this practice because we believe changing the position would result in a worse outcome as we would lose other US companies located here.