Pearse Doherty (Donegal, Sinn Fein)
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172. To ask the Minister for Finance to set down the EU countries, if any, that have officially indicated that they intend to seek tax for their own country from the payment the EU Commission ordered be made to Ireland in respect of a company (details supplied); and if he will make a statement on the matter. [31628/16]

Michael Noonan (Limerick City, Fine Gael)
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On 30 August 2016, the European Commission issued a negative Decision in the Apple State Aid case.

As a result, Ireland has been instructed by the European Commission to recover the alleged state aid from the company covering a ten year period.

The Commission has estimated that the amount is up to €13bn, but the exact quantum is to be determined by the Irish authorities.  This is to be done on the basis of a technical and detailed calculation which applies the Commission's methodology, as set out in the Decision document, to Apple's taxpayer confidential information.

In the Decision, the Commission has stated that the sums to be recovered by Ireland would be reduced if other countries were to require Apple to pay more taxes or if the US authorities were to require Apple to pay larger amounts of money to their US parent company.  Thus far we have received no official indications from any country that they intend to seek further tax for their own country as a result of the Commission's Decision.

Clearly, there is a contradiction at the heart of this Decision.  While requiring Ireland to recover the tax sums, the Commission is also acknowledging that the sums may in fact be taxable in other jurisdictions.