Apple preparing for the inevitable … (despite the Irish media spin)
Anybody who has taken the time to read the Apple tread (God bless you) will know that, with very high probability, Apple is going to be paying the Irish State €13bn plus €6bn in fines within the next year or so. We can already see in Apple’s recent 10k that they are getting ready for the inevitability of this event:
IRISH TIMES: Apple expects to offset €13bn Irish tax bill by paying less in US
Probably the most deliberately “under-reported” Irish moment of 2016, was the fact that Apple on-shoring its “stateless” IP (Appl Sales International) created “Leprechaun Economics”, made fools of us internationally, and will cost us over €300m per annum in EU GDP levies.
We covered it here:
The c €7bn extra Apple charge Margrethe Vestager uncovered without even knowing it
And even Max Keiser picked it up (via Karl Whelan, who understands these things):
MAX KEISER: [KR965] Keiser Report: Leprechaun Economics
We even still have Cliff Taylor (no stranger to taking the odd “plant” article from our Section 110 SPV thread), recently spinning the Department of Finance’s line that it was mostly Aircraft Leasing (mentioning balance sheets of €35bn). But anybody who understands Aircraft Leasing and how Irish GDP is constructed, knows that this is mis-information as the debts linked with Aircraft Leasing, make its net contribution to Irish GDP tiny. You could move the entire balance sheet of the world’s biggest Aircraft Leasers to Ireland (NAV of < €7bn) and it would be a small single digits contribution to Irish GDP (<4%). (fyi - the entire balance sheet of the world’s biggest Aircraft Leaser was not moved in Ireland in 2015).
The fact that the State wanted to hide Apple’s on-shoring (and made us fools for it), and that they still take the time to push mis-information articles via Cliff Taylor that it wasn’t all Apple (even though everybody knows it was), means that something is up.
Word on the street is that Apple, despite on-shoring its ASI balance sheet to Ireland in 2015, to escape further accrual of liability to Margrethe Vestager, are still not going to be paying anything like the 12.5% Irish tax rate. It is whispered that buried in the Finance Bill 2017, after extensive discussions with Apple’s Dublin lawyers, are the structures to allow Apple avoid all Irish taxes (again), but this time legitimately, in a way that the EU cannot contest.
And of course, if Apple’s Dublin lawyers happen to use these structures for other clients (i.e. like vulture funds in Section 110 SPVs avoiding billions in Irish taxes) who need “legitimate” shielding from all Irish taxes, then so be it. Creating (another) avenue for mass Irish tax avoidance is a price worth paying for 5,000 medium paying jobs from the world’s largest tax avoider. This is even more so when those jobs are based in Cork, home of the two Michael’s. Thus giving perfect alignment with FF and FG on this issue.
Word is also out that the EU Commission understand the gist of what the State is going to try to do for Apple, and have circulated such details in their briefings on what Europe needs CCCTB (i.e. we will never get those naughty Leprechauns into line).
We had the “Golden Goose” of Europe’s lowest tax rate.
With CCCTB, a lot of it’s benefit goes out the window.
We only have ourselves to blame.