Ireland’s Department of Finance outlined its key arguments to appeal the European Commission’s (EC’s) ruling that it had breached European Union (EU) state aid rules in its tax deal with Apple.
Arguments for the appeal
In a statement, Irish Finance Minister Michael Noonan outlined several arguments for the appeal.
First, he said, Ireland didn’t provide favorable treatment to Apple. The Chairman of Ireland’s Revenue Commissioners has stated that:
- There was no departure from the applicable Irish tax law,
- There was no preference shown in applying the law, and
- The full tax due was paid in accordance with the law.
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Facebook may have understated the value of intangible property transferred to its Irish holding company by “billions of dollars.” That’s according to a petition the U.S. Justice Department and the IRS filed in the U.S. District Court for the Northern District of California.
The petition was filed to enforce certain summonses served on the social media company in connection with outstanding information requested as part of an IRS audit. It makes the following claims: (more…)
By Sheba Dalaney, CPA, Principal
ASL International Group
Facebook may have understated the value of intangible property transferred to its Irish holding company by “billions of dollars.” That’s according to a petition the U.S. Justice Department and the IRS filed in the U.S. District Court for the Northern District of California.
The petition was filed to enforce certain summonses served on the social media company in connection with outstanding information requested as part of an IRS audit. It makes the following claims: (more…)
Facebook may have understated the value of intangible property transferred to its Irish holding company by “billions of dollars.” That’s according to a petition the U.S. Justice Department and the IRS filed in the U.S. District Court for the Northern District of California.
The petition was filed to enforce certain summonses served on the social media company in connection with outstanding information requested as part of an IRS audit. It makes the following claims: (more…)
Washington responds to Johnson Controls’ inversion to Ireland
Inversions continue in the U.S., with Johnson Controls’ deal to merge with Ireland’s Tyco International being the latest example. The plan prompted one U.S. congressman to say it shows the urgent need for Congress to act against inversions. The chairman of the House Ways and Means Committee, separately, said his panel will work toward having a comprehensive international tax reform package ready in 2017. (more…)
Update:
Ireland extends the investigation of Apple tax case. Sources suggest up to eight billion in additional taxes.
Ireland said it expects a ruling soon on whether its favorable transfer pricing rulings for Apple violated EU state aid rules. The European Commission has been investigating EU tax practices and already has ruled that Luxembourg and the Netherlands issued illegal rulings for a Fiat unit and Starbucks. This article discusses Ireland’s and Apple’s comments on the investigation.
