Results 1-20 of 59 for apple segment:6675742

Did you mean: apply segment:6675742?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

...could be recorded in the headquarters, because the headquarters did not have any employees or offices. This is why it should be recorded in the branch. We do not question or investigate how Apple organises itself. That is a matter for Apple and we do not question that. Apple has organised itself in a way such that Apple Sales International and Apple Operations Europe have a...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Ms Margrethe Vestager: We looked at two of Apple’s many companies, Apple Sales International and Apple Operations Europe. These were central to our investigation. What we saw was that Apple did not pay 12.5% of the profits recorded in the companies.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Ms Margrethe Vestager: We do not investigate or value the intellectual property. We have not done that here. We have seen that Apple has organised itself with what it refers to as a cost-sharing agreement. This means that most of the research and development takes place at the Apple Inc. facility in Cupertino. Apple Sales International and Apple Operations Europe, which are based in...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Michael D'Arcy: In his statement of last August, Mr. Cook noted that Apple took the guidance available from the Revenue Commissioners here and I can only assume the guidance was given in good faith. In those circumstances, Apple could take a case. I am asking the Commissioner if it is possible or even likely that Apple could take a case against the Irish State for the advice given by the Revenue...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Kieran O'Donnell: Section 25 of the Taxes Consolidation Act 1997 is the section under which this ruling with Apple was arrived at by the Irish tax authorities at the time. The Commissioner keeps saying that it is about state aid, but this particular section was available to be availed of by any multinational company. Under that particular section, any company is required to come up with a methodology on...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Seán Sherlock: How does the Commissioner respond to the view that Apple's intellectual property licences to the Irish branches of Apple Operations Europe and Apple Sales International are not consistent with Irish law? That is the view of our Department of Finance.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Gerry Horkan: Can I conclude from Ms Vestager's response that this is not a question of the tax code but of Apple? The ruling was on Apple, the Commissioner was examining Apple. In respect of the selectivity argument that Apple got a better deal than anybody or everybody else, how many other corporations or entities were examined? Ms Vestager referred to 14 and there are references in the report to...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Michael D'Arcy: Okay. If Apple, in good faith, took the opinion of the Revenue Commissioners to be correct, and subsequently the Commission retrospectively applied the state aid rules, could Apple take a case against the Irish Government for those moneys, including tax unpaid, and potentially another case for reputational damage to the Apple brand?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Ms Margrethe Vestager: It is not for us to proceed today on whether one finds the evidence sufficient; the lawyers will do that in court. When one looks at the two tax rulings on Apple Sales International and Apple Operation Europe, one finds that the tax rulings will give the specifics as to how to allocate profits. This is what they do, and what we have been doing is to look into this...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Michael D'Arcy: I welcome the Commissioner. In a CNBC interview, she stated:We never questioned how Apple is organized. We do not question Irish tax code, that is for the Irish. Subsequently, on 30 August, Mr. Tim Cook of Apple wrote that, over the years, Apple "received guidance from Irish tax authorities on how to comply correctly with Irish tax law — the same kind of guidance available to any...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Ms Margrethe Vestager: How many opinions? I do not know. I think the interrelationship between Apple and the Irish Government is much better answered by either Apple or the Irish Government.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Rose Conway Walsh: Does the Commissioner believe that representatives of the State sat down with representatives of Apple and arrived at a figure for the amount of tax Apple which would pay and which was not based on any normal rules? Did her investigation - at any point - note any political influences in such arrangements?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Pearse Doherty: There was a reference in the report to when Apple began to negotiate its tax liability in 1990. The Apple adviser said there was no scientific basis to the estimate of $30 million to $40 million, which would be the taxable base. In the Commission's examination of the further minutes, was any scientific basis ever provided to underpin that figure?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Ms Margrethe Vestager: I would not know that because, for obvious reasons, we have not redone the Apple organisation since we are not the tax authority and do not have the numbers of individual member states. We have not redone the Apple organisation or the value, creation and recording. My guess would be that a large majority of the unpaid taxes would be due in Ireland.

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Seán Sherlock: ...statement setting out some clear and unambiguous views relating to the ruling or interpretation of the Commission. I will quote from the statement in the context of the various entities, including Apple Inc., Apple Sales International and Apple Operations Europe. I am trying to distil this for people who may not have technical knowledge, for example, ordinary citizens who are watching...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Paul Murphy: I shall quote from Apple's 10-K form for the tax year ending September 2015. It notes: "Substantially all of the company’s undistributed international earnings intended to be indefinitely reinvested in operations outside the US were generated by subsidiaries organized in Ireland." The way Apple has chosen to organise is that all of the company's undistributed international earnings...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

...this work for them. At least, I would not be playing my part very well if that were the case because I am not a lawyer. However, 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...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Ms Margrethe Vestager: Irish law might have an issue with the way Apple sets up its operation, but that is not what we investigated. We looked at how Apple is organised and at the Irish tax system. We took those two things as a given. Our investigation was limited to how the tax rulings allocated the profits and whether the profits were to be recorded in the taxable branch or in the...

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Gerry Horkan: ...say that this particular ruling is not so much about the Irish tax system and the Irish tax code but was instigated by the US Senate hearing and is specifically about investigating and looking at Apple? Is this really all about Apple and not about the Irish tax system or rate and how we attract and retain foreign multinational companies?

Joint Oireachtas Committee on Finance, Public Expenditure and Reform, and Taoiseach: EU State Aid Rules - Investigation into Preferential Tax Rulings: European Commissioner for Competition (31 Jan 2017)

Ms Margrethe Vestager: One does not compare with Apple because the starting point is that there is selectivity due to the fact that we are dealing with tax rulings. The neighbouring company cannot use the tax rulings Apple has got. That company cannot ask for a copy and ask to do it the same way because it is specific. That is why it is a tax ruling. The reason for going to other rulings...