Seán Sherlock (Cork East, Labour) | Oireachtas source

At the joint committee meeting she attended recently, the Commissioner stated:

I can say how it looks from my side. We did not investigate how Apple organised its operations. We did not investigate the cost-sharing agreements. We did not investigate the fact that Apple records its profits in Cork, Ireland.

We were looking at whether the allocation of profits was recorded in the branch and whether, therefore, it had to be taxed in Ireland, or recorded in the stateless headquarters and, therefore, not to be taxed in Ireland. We found that the recordings by Apple, which we did not question, could not be supported by economic activity. That is why they ought to be recorded in the branch of the company that is taxable in Ireland.

I am trying to reconcile, in my own mind, the statement made by the Department of Finance on the Irish branches of Apple Sales International and Apple Operations Europe. Can the Minister give us an opinion on the Commissioner's statement, particularly on the stateless headquarters and the activity levels she says were not supported by economic activity?