Pearse Doherty (Donegal, Sinn Fein) | Oireachtas source

I did make the point but the point that the Commission makes very thoroughly is that it is impossible for all of these profits to go through a company that does not exist, that has no physical presence, no employees, no way to deal with risk, control or distribution and indeed it was the Irish division of that company which carried out all of those functions on behalf of the non-registered company. The point I am making to the Minister is that it is standard practice that if the intellectual property for products sold worldwide rests in Ireland, that is where it is taxable.

In the Commission's judgment there are minutes recounted stating there was no evidence to underpin the offer by the Apple tax adviser to calculate its taxable profits at $30 million to $40 million. Would it be standard practice that the Revenue Commissioners enter into agreements where no methodology has been written down, no profit and loss, no transfer pricing documentation and, as the Apple tax adviser says, no evidence to back up the numbers suggested?