Results 1-20 of 87 for apple speaker:Michael Noonan

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Written Answers — Department of Finance: State Aid (25 May 2017)

Michael Noonan: I propose to take Questions Nos. 78 to 80, inclusive, and 87 to 89, inclusive, together. Notwithstanding the appeal in the Apple State Aid case and the difference in view between Ireland and the Commission on the issue, the Government is committed to complying with the binding legal obligations the Commission’s Final Decision places on Ireland. Apple therefore must be deprived of the...

Written Answers — Department of Finance: Tax Collection (4 Apr 2017)

Michael Noonan: Notwithstanding the appeal that the Government has lodged in the Apple State Aid case, Ireland is required to comply with the binding articles of the Commission's Final Decision and to recover the alleged aid from Apple. Irish officials are continuing this work to ensure that the State complies with all our recovery obligations. I note the recent reported comments made by the...

Written Answers — Department of Finance: Corporation Tax Regime (4 Apr 2017)

Michael Noonan: The European Commission published the Final Decision in the Apple State aid case in December 2016.  This was sent to Ireland at the end of August 2016.  Ireland does not accept the Commission's analysis, which is why we have lodged an application with the General Court of the European Union to annul the whole Decision.  It will likely be several years before the matter is...

Written Answers — Department of Finance: Tax Code (30 Mar 2017)

Michael Noonan: The Government profoundly disagrees with the European Commission's analysis in the Apple State Aid case. An appeal is therefore being brought before the European Courts.  Such an appeal takes the form of an application to the General Court of the European Union, asking it to annul the Commission's Final Decision.  The Attorney General prepared the legal grounds in support...

Written Answers — Department of Finance: Departmental Legal Cases (28 Feb 2017)

Michael Noonan: The Apple State Aid case is a priority matter for the State. Detailed and comprehensive responses were provided to the Commission demonstrating that the appropriate amount of Irish tax was charged in accordance with the relevant legislation, that no selective advantage was given and that there was no State Aid.  This case has involved a significant degree of legal and technical...

Written Answers — Department of Finance: EU Investigations (28 Feb 2017)

Michael Noonan: The European Commission published the Final Decision in the Apple State aid case in December 2016.  This was sent to Ireland at the end of August 2016.  Ireland does not accept the Commission's analysis, which is why we have lodged an application with the General Court of the European Union to annul the whole Decision.  It will likely be several years before the matter is...

Written Answers — Department of Finance: State Aid (28 Feb 2017)

Michael Noonan: On 30 August 2016, it was announced that the Commission had issued a negative decision in the Apple State Aid case.  The Government remains of the view that there was no breach of State Aid rules in this case and that the legislative provisions were correctly applied.  By appealing the Decision the Government is taking the necessary course of action to vigorously defend the Irish...

Written Answers — Department of Finance: State Aid Investigations (9 Feb 2017)

Michael Noonan: The European Commission published the Final Decision into the Apple State Aid case in December 2016. This document was sent to Ireland at the end of August 2016. Ireland does not accept the Commission's analysis, which is why we have lodged an application with the General Court of the European Union to annul the whole Decision. Notwithstanding our appeal, Ireland is obliged to comply...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...committee for inviting me to attend today to discuss this important issue. The topic of today's discussion is the subject of ongoing litigation before the European courts involving the State, Apple and the European Commission. As a result, I am required to fully respect the constraints placed on me by both Irish and EU law as regards public discussion on open legal proceedings. This...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...that country was demanding that the Government there should seek claims. The difficulty about this is that it suited the Commission that other countries would come in and start demanding extra tax from Apple. It meant that Ireland would be left with few friends when other people around the table thought there was a windfall due to their countries. From a public relations point of view,...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: No, we cannot take it off the table because the Commissioner is not doing so. The Commissioner has said that there is a possibility that countries which believe that Apple did not pay sufficient tax in their jurisdictions could make claims against the escrow account of the €13 billion when this is all resolved, if that is the way it goes. We cannot take it off the table because we...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...to be absolutely certain of the detail in retrospect. The first opinion was in 1991, which is 26 years ago. The Senator may recall, if she has done some research into corporation tax, that Apple came to Ireland in 1980. Right through the 1980s - like other exporting companies - it had export sales relief. Export sales relief meant that exporting manufacturing companies paid zero tax....

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: Multinational companies structure themselves in different ways. Some of the structures are quite complex. It does not just apply to Apple. In Ireland's case, the legal advice and the opinion of Revenue was that only the profits generated from economic activity in Ireland were taxable. Apple paid the full 12.5% on the profits made on the economic activity in Ireland.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...that the profits made by non-resident companies were not amenable to Irish tax. They were amenable to tax back where the parent companies were in the United States. The assumption was that while Apple did not pay tax on the profits which were accrued to the United States, they had a tax liability at 35% but that tax liability would only be crystallised into tax paid if the profits were...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...share, that multinational companies, because of the mismatch of tax law in different jurisdictions, are not paying the amount of tax they should be paying. That is not the issue. I do not think Apple was paying sufficient tax worldwide. The argument is that the tax liability was not in Ireland; it was where the economic activity occurred. One can see the big debate that is starting...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...decision and instead Ireland is required to calculate the sums on the basis of the methodology set out in the decision. The work has been ongoing since September 2016 in co-operation with the Commission and Apple but so far my officials have not indicated to me that it will seriously over-run the €13 billion or come seriously short of it. There are other years to be assessed.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...rates. The interest is calculated on a compound basis and the interest rates will only cease to apply on satisfaction of the recovery order, that is, on payment. As soon as the payment is made by Apple the interest calculator stops running.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...international norms, only allows us to tax non-resident companies on the profits they make in Ireland. The central aspect of this case is that the economic activity that created the value in Apple's business operation was not conducted in Ireland. Everybody knows that the iPhone and other well-known Apple products were developed in the US, not in Ireland. The bulk of the profits,...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: ...world is paying 0.01% or an amount of that nature - a figure which the Commission has put into the public domain. Of course, that is true and I would not stand over it either. The point is that Apple had a liability of 35% for the profits that accrued in the United States but under the law in that jurisdiction, the tax liability only crystalises if the company repatriates the property....

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: Minister for Finance and Office of the Revenue Commissioners (2 Feb 2017)

Michael Noonan: It would be more accurate to say we are being asked to collect tax on profits accruing to Apple for economic activity that was outside the island of Ireland.