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September 13, 2016


Eoin Ó Murchú

Astonishingly naïve not to recognise that the state aid nonsense is just an excuse to make sure that it's Brussels not Ireland that lays down rules on the consolidated tax base issue.


Mr ÓMurchú seems to assume that the Inspector who handled the matter in 1991 & 2007 was not experienced with an in-depth knowledge of transfer pricing.

A clear assessment was made of the activities of the Apple Cork operation, costs incurred, capital employed, quality of work etc. An expected profit for the type of operation if the contract was negotiated at arm's length was calculated and agreed.

The error made was one of omission. The Irish Revenue chose to conveniently ignore profits properly assessable in other jurisdictions, were assessed there, or anywhere.

Mr. ÓMurchú also chooses to ignore the settlement made by Apple Italia with the Italian authorities, which was specifically in connection with the relationship between Apple in Ireland and Apple Italia.

Even a short perusal of M Vestager's statement would show that this case has nothing to do with CCTB. A point clear emphasised by Jim Stewart. Indeed Apple have a completely different tax structure now in place, for the introduction of BEPs. However, if anything, the Apple settlement with the Milan prosecutor Dr. Greco raises a wider range of issues, not considered by M Vestager.

However,as usual he never let facts get in the way of his version of the story!

Dirk Jansen

Unite say the Apple bite could range from €13bn to as low as €2bn, or less, depending (a) on Apple settling (b) Apple appealing (c) Other countries claiming/not-claiming their share (d) not adding that U.S. may want the tax anyway.
There are 6000 jobs in Cork, which have not cost anything like the 'imaginary' €200,000 per job, annual subsidy. To my knowledge Unite have not built and plants anywhere in Ireland, have employed a modrate amount of staff, whom they do not pay, a yearly average of around €80k, to and are just bad-tempered because they will not get a bite of any apple. I would hate to be the Taoiseach who might be accused of throwing away 6000 jobs, in a city, still reeling from the effects of the closure of Dunlops and Ford, many years ago. If one compared it to Dublin, where proportionately 60,000 jobs would be in the balance, for a bite at a tantalising apple, then more sense might be made of the decision to appeal the, slightly, capricious EU ruling.

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