ECJ upholds commission decision on apple tax case

Well done the EU for holding us and Apple accountable. One of the many advantages of being an EU member - there are adults outside of this country to make decisions for us.

We keep being told there is a pension time bomb coming down the tracks.

So let's put it into the pension reserve fund for the future. It will be needed.

I think you mean asserting that Revenue and, by extension, Ireland had not give any illegal state aid to Apple. What many don’t realise is that the case did not even decide that position as one significant aspect of the decision is that the failure of Apple to provide evidence to the Commission in the initial stages meant that it should not have been able to rely on it at the General Court. The ECJ determined that the the GC erred in allowing that evidence (of the activities outside Ireland) to be taken into account in its decision. As such that is a procedural problem, arguably we still don’t know if the tax treatment (based on documents published by the OECD in 2010 and not followed in many jurisdictions before then) constituted state aid.

Sure it could always be worse.

https://news.sky.com/story/mps-vote-to-cut-winter-fuel-payment-for-millions-of-pensioners-13212264

Anyway not happy at the ruling, another example of the EU overstretching their authority. That money will be pissed away on tax cuts and welfare increases over a few years, heating up the economy even more.

More on housing? Can't build enough as is with money not a problem.

Health? That thing is just a black hole that could swallow the lot in a year.

Unless it can be spent on major infrastructure projects just throw into the pension fund.

Nobody from Government available to go on Prime Time.

Surprise surprise.

PS id be delighted with a decent tax cut.

A €300,000 bike shed in every house.

OK, thanks.

So, in essence, some of Apples profits will have been taxed twice, in the end? By us and the USA?

The profits of ASI were always going to be taxed by the USA, eventually.

Yes, and build a proper state of the art nursing home in every town that needs one.

as I stated upthread, the deemed repatriation arising fromTrump’s TCJA will have brought this income into US tax net but without a foreign tax credit for the Irish tax. They could not have claimed one as Ireland asserted it was not due.

IFSC was a subseq of “manufacturing relief” as were tech services. From inception, they were due to be gone by 2005 (IFSC) and 2010 (actual manufacturing). From 1997 (by memory), there was already a discussion of reducing headline rate of CT down to 15-17% to give same yield. When I started working in tax in 1989, headline rate of CT was 50%.

We already run a hefty budget surplus even before the €13 Billion. We massage this down by paying most of this money into 2 special reserve funds (Infrastructure and Pensions). One big reason is that the economy is at full employment and extra spending just bumps up against ever more supply constraints with inflationary results.

So the €13 billion should either be used to bolster these funds further (some day we will really need the money), or even to pay down debt, which is still quite high in relation to GNI* (forget about GDP, whihc is totally distorted for Ireland).

But this would drive the Shinners and PBP into well-publicised apoplexy on RTE.

The 14 billion should go straight to paying down the National debt and we move on like nothing happened...

End of story...

No it shouldn't.

We would have to buy back or own debt at less favourable rates than we have at the minute.

It would probably be short sighted however to "blame" the EU here when attempts by nations to offset the tax advantages of other nations will always be a feature of the globalised economy. If the EU disappeared tomorrow, this wouldn't change. Europe would still have its foremost powers in France, Germany and the UK and these countries would still exert political pressure on Ireland's taxation system if they wanted — and a group of likeminded nations (which could include the US) could find several ways of landing blows on us as a pressure tactic.

If anything, at least the EU legal system offers the opportunity for legal recourse and fair procedures.

Much like Brexit exposed, I think people labour under a particular illusion that departing the EU (or indeed the dissolution of the EU) opens this pathway to ultra sovereignty where you can just more or less do as you please and without a Brussels overlord to prevent it, the world just kind of accepts it and accommodates it. The reality is that — remove the EU from the picture — and countries will just squeeze us on our tax rate by other methods.

It would not be a matter of buying back debt. A lot of existing debt matures from year to year, so instead of replacing it with new debt issues, we just repay the principal and do not have to borrow to replace old debt with new debt.

I'm sure all the Gombeen Men will be out to wet their beaks soon.

You'd have to wonder at the competence of the EUs legal system when the higher court says the lower one erred in its judgement. Like a lot of law, I wonder how impartial or fair it really is when the outcomes seem arbitrary like this case. A judgement can be reasoned, but the exact opposite was also reasoned.

On the latter point about the beginning of end of the EU love-in. I'm not saying the Irish establishment is about to do a volte face and become eurosceptic. I'm thinking it will be return to a more 1990's posture where derogations are exercised and opt outs are kept. In the past 20 or so years hard won opt outs have been frittered away and traded clearly to keep taxation off the table. Well the taxation advantage and the opt outs are gone now.

What's good for Europe is not always good for Ireland and I think following this ruling this obvious reality will dawn on some in officialdom