Apple Tax issues in Ireland

Associate
Joined
6 Sep 2006
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728
Ah ok i wasnt sure if vat always went to the country the item/service was being used in if you get me.

Like a say a phone, subscription and app is bought in the uk but all routed through the "apple international" in ireland that the 20% vat would go to the uk,.

Because otherwise wouldnt all apple sales include 23% vat not 20?

Place of supply rules vary between goods and services and whether supplies are B2B or B2C.

Broadly, VAT is meant to be suffered in the country where the goods/services are consumed. Certainly, on phones, VAT will go to the country where the phone is sold to the consumer (unless it's part of a MTIC scam :))
 
Associate
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6 Sep 2006
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728
Actually that is just the first step. They are now going to reassign the taxes to the countries in the EU they occurred in which will increase them significantly. They have asked all EU countries to calculate what was incurred in their country. This change will certainly result in Apple and other organisations with this arrangement to move to another country.

That's currently just BEPS - and it's a OECD initiative rather than simply EU. I'm personally pessimistic and it assumes large scale co-operative working between countries that ordinarily compete with each other agressively for inward investment.
 
Caporegime
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30 Jun 2007
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Location
Wales
Place of supply rules vary between goods and services and whether supplies are B2B or B2C.

Broadly, VAT is meant to be suffered in the country where the goods/services are consumed. Certainly, on phones, VAT will go to the country where the phone is sold to the consumer (unless it's part of a MTIC scam :))

My brain hurts.
 
Caporegime
Joined
30 Jun 2007
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68,784
Location
Wales
This issue is clearly too complex to be dealt with easily, but bear in mind that Member states still have complete discretion over tax rates.

The Commission's position is that Ireland's actions in not enforcing its 12.5% rate with Apple amounted to a sp[ecific, special deal with Apple and hence isn't covered by the exemption and amounts to state aid.

Commission's argument will probably fail, since I'm willing to bet that a host of other large US companies did exactly the same - once Ireland can demonstrated that Apple had no special treatment, I can't see the state aid argument succeeding.

Would ireland not have to prove ALL companies had the same deal though?

As otherwise its just several companies receiving special deals.
 
Soldato
Joined
31 May 2009
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21,257
Indeed, I don't really see what legs they have to stand on, but they will 'fight the good fight' knowing that if they lose they gain a windfall from Apple, who by then will rebrand, be bankrupt and won't have any employment in Ireland anyway.

They are unlikely to lose jobs over this, no matter what scum cook says, he isn't the evil tyrant scum jobs was, but they will need to base themselves somewhere, and Ireland still has the best rates available.

I just don't quite get the figures, if the EU said apple paid an actual rate of 0.005% in 2014, just how much did this equate to?
 
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