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Apple must pay 13B euros in back taxes, EU's top court rules

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Re: Apple must pay 13B euros in back taxes, EU's top court rules

#661

Post by pmontra »

robertlagrant wrote: post #654
sensanaty wrote: post #622

Earlier quoted context omitted.

If I were an Irish citizen paying taxes I'd be incredibly pissed that my own government is fighting against 13 billion from the richest company on the planet. I'm subsidizing fucking Apple of all things!? Absolute buffoonery, whoever made this deal in the first place should be in prison.

They're not subsidising Apple. Apple is providing thousands of jobs - they pay taxes on those people, and those people pay income tax / VAT / fuel tax / death tax / etc and they consume from other companies that pay lots of taxes as well, and import tariffs as well. It's taxes and tariffs all the way down. No one is paying Apple money. It's not a subsidy.

There are Irish customers buying Apple products. Some of that money goes into the salaries of Irish Apple employees, which pay their taxes in Ireland. Some of that money goes into other expenses in Ireland. What's left goes to the USA where Apple pays taxes on the part of them that turns to be a profit. The idea is that part of that money (the tax) should not go to the USA but stay in Ireland. In that way the money of Irish customers would stay in Ireland, which is probably good for Ireland but it's a matter of opinions.

There is also a 15% corporate minimum tax of big corporations, in effect since the beginning of this year [1] I think that there are many ways to keep circumventing even this attempt at keeping EU money inside the EU, but we will see.

[1] https://taxation-customs.ec.europa.eu/taxation/business-taxa...

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#662

Post by piltdownman »

lm28469 wrote: post #641
piltdownman wrote: post #636

Earlier quoted context omitted.

Germany has the Rhine and is the centre of the continent, and also has the Marshall Plan boost post 1950 for their infrastructural development. Ireland is an Island whose population only hit pre-famine levels in the last 3 years. Of course our economy is going to skew heavier service based! How are you going to ship cars and heavy industrial goods from Ireland to the rest of the EU and compete with Germany or France…

If you can't be intellectually honest and accept that Ireland would be a fraction of what it is without its tax evasion system idk what to say, there is literally not a single source that will tell you otherwise, even their own official reports mention that it is the case. When 25% of your GDP comes for a single foreign company with 6000 employees in your country it's time to raise an eyebrow, especially when the fac…

We don't use GDP because we're not a bloody Coal and Steel Union in the 1950s, we're a Service based economy in a Globalised marketplace.

We use Modified GNI (GNI*) - GNI minus the depreciation on Intellectual Property, depreciation on leased aircraft and the net factor income of redomiciled PLCs - which accounts for almost all of what you're citing bar some more egregious BEPS tools which are closed for years.

For someone regurgitating Wikipedia, you're avoiding the obvious article. https://en.wikipedia.org/wiki/Modified_gross_national_income

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#663

Post by piltdownman »

realityking wrote: post #443
piltdownman wrote: post #120

Earlier quoted context omitted.

All tax treaties and agreements between countries (including intra-EU) are bilateral country to country agreements. Most are refreshed every 3-7 years based on OECD (or EU) recommended standards. Ireland's laws and treatment are 100% compliant. Rather than competing and reducing their tax rates countries like France prefer to moan, as politically they can’t be seen to favour big bad businesses. This of course was no…

> All tax treaties and agreements between countries (including intra-EU) are bilateral country to country agreements. That is completely wrong on multiple levels. - You’re likely thinking of the double taxation treaties that follow the OECD model convention. These hardly get refreshed every 7 years. The German/Irish one is from 1962, the French/Irish one is from 1966, and the UK/Irish one from 1976. - The OECD’s BEPS…

TBF VAT is its own special category which I'd omitted so I'll give you that.

OECD BEPs isn't a tax treaty per se, its a Multilateral Convention to Implement Tax Treaty Related Measures.

Re: the Nordic treaty, Norway and Iceland aren't in the EU.

> The German/Irish one is from 1962

Correct. Here's the 1962 version https://www.revenue.ie/en/tax-professionals/documents/double...

and here are the last three UPDATED versions

https://www.revenue.ie/en/tax-professionals/documents/double...

https://www.revenue.ie/en/tax-professionals/documents/double...

https://www.revenue.ie/en/tax-professionals/documents/double...

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#664

Post by piltdownman »

SJC_Hacker wrote: post #658
AnthonyMouse wrote: post #570

Earlier quoted context omitted.

The problem with all of this is that it's all sneaky schemes. You probably have something in mind for how a government is supposed to spend tax revenues. Assistance for the poor or something like that. But as a sovereign state they get to decide for themselves. Except that as soon as you admit this there is no point in having any kind of minimum rate etc., because there are a thousand ways for the state to return the…

> sovereign state Well thats the rub, by being a part of the EU they are effectively semi-sovereign. Not to sound like a Brexiter

No, we entered a common trade market. We're not even part of Schengen. We're an odd fish in terms of EU membership overall given our geographical position, size, and CTA with the UK.

We are the only EU member state that are obliged to hold public referendums on Treaties. Ratification of the Treaty in all other member states is decided upon by the states' national parliaments.

Ireland, Netherlands, and Luxembourg also have veto powers when it comes to EU wide regulations.

In short, if we didn't have so many of our national parliament trying to appease the bureaucrats in the EU so they could land cushy numbers in the European Parliament for retirement, you'd see a lot more sabre rattling from Ireland regarding EU interference.

Atm however, we have a lot of issues with Asylum legislation that has to be dealt with as prioirty https://en.wikipedia.org/wiki/Dublin_Regulation

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#665

Post by Silhouette »

toyg wrote: post #653
Silhouette wrote: post #526

Earlier quoted context omitted.

Do you really believe Apple-Ireland is the only cosy tax-based incentive that any EU member state has offered to any international company to invest and operate locally in the past 30 years? What's next? All the member states that offered attractive VAT rates when the regime was different years ago and doing so was advantageous retrospectively get reset to some baseline rate around the bloc's average and every compan…

> Do you really believe Apple-Ireland is the only cosy tax-based incentive that any EU member state has offered to any international company Cases are prosecuted if someone (either competitors or the Commission) thinks they're worth the trouble. Apple and Google were clearly worth it, simply because of the massive amounts of money involved - nobody cares if an ice-cream stall is foregone 100 euros. If you know of oth…

I don't see what you think is mischaracterised here. Lots of companies have received individual favourable tax treatments within the EU in ways that would not fly today. Several member states have historically established competitive tax environments at the likely expense of their fellow members too. As I said before it is unrealistic to argue as if Apple and Ireland is the only such case.

And I doubt that retrospective VAT change would still be very popular after trading with the EU became completely toxic - which is not an unrealistic outcome from such a hostile act. Businesses already avoid EU customers because of the existing environment. Retrospective demands for more money would be much worse.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#666

Post by Silhouette »

noirbot wrote: post #649
Silhouette wrote: post #645

Earlier quoted context omitted.

Creating an ambiguous business environment is unfortunately a recurring pattern with the EU. A few years ago we had some fierce debates on HN about EU measures like the GDPR. Some claimed the regulations were excellent and compliance was easy if you weren't doing anything wrong. Some were more cautious and thought the length and frequent ambiguity of the regulations meant it couldn't be that simple. The strident defe…

And much the same with Apple and the DMA most recently. Do I think Apple is being a bad actor re: the DMA? Yes. But it does also seem like the EU is doing a lot of "Well, just release your product and we'll tell you after you ship it if we're going to fine you for billions of dollars". You see this with things like the upcoming iPhone Display Mirroring features that aren't coming to the EU where Apple has said they'r…

See also certain popular and state of the art models in AI, which are not available in the EU because of similar fears. Sometimes it's like the EU and its defenders think the EU is too big for businesses to walk away no matter how hostile the environment becomes. This is unrealistic.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#667

Post by robertlagrant »

pmontra wrote: post #661
robertlagrant wrote: post #654

Earlier quoted context omitted.

They're not subsidising Apple. Apple is providing thousands of jobs - they pay taxes on those people, and those people pay income tax / VAT / fuel tax / death tax / etc and they consume from other companies that pay lots of taxes as well, and import tariffs as well. It's taxes and tariffs all the way down. No one is paying Apple money. It's not a subsidy.

There are Irish customers buying Apple products. Some of that money goes into the salaries of Irish Apple employees, which pay their taxes in Ireland. Some of that money goes into other expenses in Ireland. What's left goes to the USA where Apple pays taxes on the part of them that turns to be a profit. The idea is that part of that money (the tax) should not go to the USA but stay in Ireland. In that way the money o…

Is this the case, though? How much profit is generated by Irish Apple customers compared to the giant amount of tax paid in the country due to Apple being there?

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#668

Post by gamblor956 »

pembrook wrote: post #660
gamblor956 wrote: post #473

Earlier quoted context omitted.

Many types of income cannot be offset nor or they covered by tax treaties. That's news to me and I've been doing international tax for 15 years. Please, tell me what types of income earned by a U.S. expat isn't covered by a tax treaty? It is not uncommon to pay more taxes in aggregate as an expat than you would pay in either country separately. This is objectively false. For an expat, income taxes paid to a resident…

You clearly haven’t dealt with many of the edge cases then. If you make over $150k as an expat and have a non-American spouse (MFS, as many expats do) you’re looking at roughly $1-$5k in extra taxes that don’t qualify for the Foreign Tax Credit, and since they’re above FEIE, you effectively get double taxed. You can then take that to the country you reside, IF they have a tax treaty with the US, and apply for a credi…

If you make over $150k as an expat and have a non-American spouse (MFS, as many expats do) you’re looking at roughly $1-$5k in extra taxes that don’t qualify for the Foreign Tax Credit, and since they’re above FEIE, you effectively get double taxed.

Yes, if you have a bad accountant. If you're getting double-taxed on your global income as an American expat, your tax preparer is committing malpractice and you should immediately find a new one.

When Europeans move to the US, the IRS doesn’t say “let’s see how much gains you’ve accrued in your national pension fund and tax them yearly.”

Because we have tax treaties that address this with over 100 countries (including Protocols (updates to treaties) that address older treaties which were ambiguous on the issue of retirement income).

You can then take that to the country you reside, IF they have a tax treaty with the US, and apply for a credit which may or may not be accepted

This is false. If the treaty applies, you don't get a tax credit...because you aren't being taxed. Conversely, if you are taxed, you will get a tax credit regardless of whether there is a treaty because all major countries have a foreign tax credit regime.

Always humorous to see people who don't know anything about tax opine like they do just because they read a few things on reddit or HN and suddenly decided they were experts.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#669

Post by stiray »

TMWNN wrote: post #648
stiray wrote: post #559

Earlier quoted context omitted.

Here you have tons of USA citizens living in EU (and around the world) and ask them for first hand expirience on alternative. https://www.youtube.com/watch?v=D1yT8swtVvg Dont miss part 2, part 3,... and skip non health care related, you might not want to hear them. And anyway, believe me that everyone rather waits in line (which is not really the case, if you are an urgent case, you trough the line), that not even go…

>Here you have tons of USA citizens living in EU And yet, the only country in the world with more Americans living in it than the other way around is Australia.[1] Revealed preferences expose the truth that no number of videos with cherry-picked participants do not. [1] That's on an absolute basis. Since the US has 20 times as many people as Australia, the odds an Australian will move to the US is still far higher th…

Sure, you have quite a few USA citizens living in Australia talking about how messed up the USA is. You just need to study the material.

And feel free to show "cherry picked" material, where such amount of people are claiming otherwise. From the people that have left USA for more than vacations.

Did you?

Asking as I have always loved this Mark Twain quote, “Travel is fatal to prejuidce, bigotry, and narrow-mindedness, and many of our people need it sorely on these accounts. Broad, wholesome, charitable views of men and things cannot be acquired by vegetating in one little corner of the earth all one's lifetime.”

I regularly use it on local far right "peasants" in my country, that are sure, there is nothing better than their own turf while never stepping far away from it.

Re: Apple must pay 13B euros in back taxes, EU's top court rules

#670

Post by [deleted] »

qwytw wrote: post #483
gunapologist99 wrote: post #421

Earlier quoted context omitted.

.. thus removing a significant portion of income from these so-called tax havens, which generally tend to be poorer countries. No one has accused Germany of being a tax haven, for instance.

> so-called tax havens, which generally tend to be poorer countries Smaller, not poorer. Unless you think that current or historical "tax havens" like Ireland, Luxembourg, Netherlands, Switzerland etc. were/are poorer than Germany. If you have less than a handful of million people even getting a few percent + several thousands of jobs from corporations like Apple is a huge deal. It would be a drop in the bucket for G…

[deleted]
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