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Apple has €13bn Irish tax bill overturned

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Re: Apple has €13bn Irish tax bill overturned

#211

Post by mrep »

ksec wrote: post #191
mrep wrote: post #150

Earlier quoted context omitted.

Why is that? Like, on the US west coast, ballooning home prices makes sense because their cities are in valleys with a fixed amount of land, but munich looks like it has a bunch of farmland around it that could be converted into housing increasing supply and thus decreasing prices. This coming from someone in chicagoland which has 9.5 million people but housing isn't crazy because the metro area sprawls 30-40 miles o…

I think it has more to do with world wide's low interest rate which is pushing asset prices to sky rocket. You now get a fast shrinking middle class and dismal living condition in lower class. Of course, they could have combated this with more supply. Not sure if they have done so.

Low interest rates certainly allow you to afford a more expensive home, but inflation adjusted price per square foot isn't actually skyrocketing for most of the US outside of the west coast [0]. For example, Dallas/Fort worth and Houston metro populations, the 4th and 5th largest in the US have both grown a whopping 19% in the past decade and prices aren't skyrocketing there. But they have plenty of land surrounding their cities that can be developed to increase the housing supply.

It just seems weird to me. Why are people paying such high prices when there is farmland so close by that you could buy and use to build some condominiums, townhomes, duplexes or even single family homes.

[0]: https://www.supermoney.com/inflation-adjusted-home-prices/

Re: Apple has €13bn Irish tax bill overturned

#212

Post by chris_wot »

secondcoming wrote: post #154
m12k wrote: post #20

Transfer pricing and tax havens are draining money out of the economies of most European countries, breaking the virtuous cycle where consumer spending also leads to salaries, taxes and more investment in the community, to keep the economy going - instead we have a shrinking middle class, as the fuel is drained from the engine. Ireland, Luxembourg and certain other countries are complicit in this. We clearly need bet…

Apple has been in Ireland since the 1980's. A large fraction of an entire city (Cork) depend on it. It's not hard to imagine that Apple has contributed far more than $14bn to the community, and country, in that time. And it's not a figure-head office either, it has assembly lines. Countries aren't all identical. Ireland needs to be allowed tune its economic policies based on what it has to offer. It doesn't have the…

Double Irish with a Dutch sandwich... yum!

Re: Apple has €13bn Irish tax bill overturned

#213

Post by soneil »

ksec wrote: post #200
soneil wrote: post #170

Earlier quoted context omitted.

It all gets terribly murky very quickly. For example, we often claim one of our strengths is that we have a highly educated workforce - but this is circular; people take this path because they know there's good work at the other end of it. If we ripped out those MNCs, that highly educated workforce would vanish quicker than you can say J1. There are other benefits to being in Ireland. We have a common-law legal syste…

>(or perhaps the only factory outside the US?) The only one I know is in US making Mac Pro. Interesting, what else is assembled in Cork ? If I buy an iMac in UK, would it be assembled in Cork? Why is a plant in Cork entry to EUR? Couldn't those be shipped from China? ( Considering this is Apple related I cant be the only keep reading Cork as Cook XD )

I believe the Austin plant is owned/operated by Flex / Flextronics. Although I see some news blurb that Apple are building a campus out there too, so perhaps that's going to change in the future? As I understand it, it's all contracted out in various places - save Cork as one very odd exception.

For the UK - possibly. The only product I'm aware of, is that they build configure-to-order iMacs. I have no idea how far they distribute from there, but I think it's a safe assumption that they don't maintain this facility just to ship CTO iMacs to Ireland. So I'd consider the UK a safe bet, and most likely most of EMEA. Could they be shipped from China? Most probably - my CTO MBP was. I have no idea what their reasoning is. (Although I'm almost certain it's not all they do in Cork - they have a second campus in the city centre, which wouldn't make sense for manufacturing.)

But for Cork being a foothold into the EU - Cork is their EU headquarters. The company operating there is Apple Distribution International Ltd, not Apple Inc. This is a large factor in how the finances are set up (at least as I understand it) - a mac sold in the UK goes on the books at ADI Ltd, Ireland - not Apple Inc, Cupertino. And this is how "Apple" ends up holding huge amounts of cash outside of the US. Their right hand is an American company, but their left hand is an Irish company. So the US only taxes them on funds held in their right hand.

If you're in Europe, and you have any email receipts from buying things from the mac/ios app stores - scroll to the bottom and check the address. There's a very strong chance it's not Cupertino.

While I'm on a ramble - I also find it curious that Apple don't have a single physical retail presence in Ireland. There's an Apple store in Belfast, but not in Dublin - despite Dublin having 5x the population. I have a strong suspicion this is not a coincidence either.

(I have absolutely no relationship with Apple other than as a customer - this is all just my understanding based on paying attention, and absolutely no inside knowledge. Obviously, else I'd be screwed right about now, eh?)

Re: Apple has €13bn Irish tax bill overturned

#214

Post by nfsdjkghewyuh »

sharkmerry wrote: post #119
jonfw wrote: post #107

Earlier quoted context omitted.

I feel like this argument lacks a full understanding of what 'net worth' even means. Bezos is not taking enough cash from Amazon to be even remotely relevant to what they pay their warehouse workers. His cash compensation in 2019 was 1.6 million. Not sure how that reflects in 2020, 2021, but the point is that Bezos is only absurdly rich in theory He is theoretically worth hundreds of billions- but his actual consumpt…

> There is no direct link between Bezos net worth and allocation of resources to laborers, and attempts to paint that picture are misguided. If they raised wages of factory workers, profits go down, stock goes down, Bezos net worth go down. no?

More likely if factory workers got better wages then prices of goods would go up, demand would go down, and some factory workers would no longer be needed. Amazon doesn't have the luxury of deciding it doesn't want to create value for it's shareholders, and I'm speculating widely, but I'm guessing the marketplace (B2C) aspect of the business is probably operating on much slimmer margins than the cloud aspect (B2B). If they were to subsidize the marketplace with cloud profits, it would be anti-competitive. They would be operating at a loss which would prevent competitors from being profitable and competitive.

Re: Apple has €13bn Irish tax bill overturned

#216

Post by secondcoming »

rusk wrote: post #197
secondcoming wrote: post #154

Earlier quoted context omitted.

Apple has been in Ireland since the 1980's. A large fraction of an entire city (Cork) depend on it. It's not hard to imagine that Apple has contributed far more than $14bn to the community, and country, in that time. And it's not a figure-head office either, it has assembly lines. Countries aren't all identical. Ireland needs to be allowed tune its economic policies based on what it has to offer. It doesn't have the…

> A large fraction of an entire city (Cork) depend on it That is not true. They employee a few thousand people in an industrial estate outside a suburb of cork in fairly low ranking jobs. If they were to disappear overnight they would doubtless have an impact but not a fraction of €14bn

Not these days perhaps, but back in the 1990's it would have. Who else was there, EMC?

And if Apple did leave it's not unrealistic that the reasons that made them leave would also be on the minds of the other multinationals in the area.

Re: Apple has €13bn Irish tax bill overturned

#217

Post by elindbe2 »

ChuckNorris89 wrote: post #168
mrep wrote: post #150

Earlier quoted context omitted.

Why is that? Like, on the US west coast, ballooning home prices makes sense because their cities are in valleys with a fixed amount of land, but munich looks like it has a bunch of farmland around it that could be converted into housing increasing supply and thus decreasing prices. This coming from someone in chicagoland which has 9.5 million people but housing isn't crazy because the metro area sprawls 30-40 miles o…

Because Germany is mostly old money, inherited for generations, that is very risk adverse so instead of investing it in new SW companies or buying stocks, they park it in real estate in desirable areas and prop up this bubble since it's a sure bet for a return on investment. That's why they call it Beton Gold ("concrete gold").

That doesn't explain the lack of new building though. Is it NIMBYism?

Re: Apple has €13bn Irish tax bill overturned

#218

Post by netcan »

m12k wrote: post #171
netcan wrote: post #145

Earlier quoted context omitted.

Is it a race to the bottom though? I mean, a race to the bottom in the normal sense is cutting taxes or spending money on attracting these companies. We help these companies evade other countries' taxes, not our own. Also, officially, the entities involved in the tax evasion are not related to the entities that actually employ people. Would Google move it european customer support offices without this tax deal? Theor…

> Is it a race to the bottom though? It's a race to the bottom as soon as any of those other countries undercut your tax rate to try to steal the MNCs back. Most countries realize that isn't sustainable, so for now it hasn't happened.

Well... it's been 30+ years.

Re: Apple has €13bn Irish tax bill overturned

#219

Post by toast0 »

627467 wrote: post #114

> "This case was not about how much tax we pay, but where we are required to pay it," Apple said in a statement. We have come to accept that certain tax payers (ie. corporate or well lawyered individuals) can chose where their revenue should be taxed. It think it has become obvious that this freedom distorts the spirit of taxation in most (all?) countries. I think it is fair to prevent double taxation across countrie…

> IMHO revenue should be taxed as close to the source (revenue-generating-event) as possible.

What is the source of the revenue of an item sold in country A, manufactured in country B, and designed in company C?

What if it was shipped into country A, but the shipper has no nexus in that country? What if it was manufactured in country B, but the designer has no nexus in that country?

Add in parts made in one country, and assembled in another for more fun.

The new US corporate tax plan has an interesting approach of AMT on corporations of X% of global income or Y% on US income, whichever is more, with AMT credits for foreign taxes paid; and the income doesn't need to be repatriated to be taxed. (IIRC, X is 10, Y is 20). Of course, that only is effective if the company is US homed, if it only has a US subsidiary, that can't be used to levy a worldwide tax.

Re: Apple has €13bn Irish tax bill overturned

#220

Post by elindbe2 »

thehashrocket wrote: post #165
mrep wrote: post #150

Earlier quoted context omitted.

Why is that? Like, on the US west coast, ballooning home prices makes sense because their cities are in valleys with a fixed amount of land, but munich looks like it has a bunch of farmland around it that could be converted into housing increasing supply and thus decreasing prices. This coming from someone in chicagoland which has 9.5 million people but housing isn't crazy because the metro area sprawls 30-40 miles o…

If we keep plowing over farmland to build suburbs where will the farming get done?

In areas not close to Munich?
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