Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, CCCTB


#81

They actually averaged around $600K/$700K back then. Around $300K on selling computers. A typical software company made about $300k/400K. Although a lot only got $200K… Numbers have not changed that much since then, accounting for inflation. Consumer electronics is a low net margins business.


#82

Ouch :laughing:

14m: @brianmlucey Have they your number Brian I hear your man Observer on ThePropertyPin is free on Sundays

bijlmer arena

#83

independent.ie/opinion/columnists/colm-mccarthy/us-treasury-is-owed-the-tax-that-apple-has-avoided-35019476.html

Colm Mc seems to confirm the connection of the 26% GDP jump to Apple in the above (as raised here during the week). He also pulls off the stroke of using Quantum Mechanics to elucidate the whole thing which is a bit of a Tour de Force.


#84

So how do we square this with th statement by the Revenue Commissioners that:

It seems that this is, at best, misleading at at worst false. If the Dail is being mislead by Revenue, there’s a bigger problem re tax policy.


#85

Bah, that’s nothing. :smiley:
Ardagh Glass Sales
31st Dec 14 Source: CRO

€459.5 million turnover
€27.9 million profit
2 employees

With numbers like that, one has to wonder just how much useful analysis of these bare data is possible.


#86

McCarthy manages his usual stunt of being both right and wrong at the same time. The Money Apple stashed in Ireland is not owed to the US Revenue because the scheme was designed to ensure that ANYBODY but the US revenue would get it. It is owed to global Revenues everywhere an iPhone is sold more like.

The 26% jump in GDP in Q1 2015 was in large part a legal redomiciling of 100s of aircraft in a Leasing Fleet to Ireland and not all Apple faffle like McCarthy wrongly said.

He is correct in pointing out that other countries are moving towards Ireland like rates of Corporation Tax but as the UK deficit is again too high in 2016, and headed for 4% rather than a forecast 2.9% precisely then their gallop downrate will be slowed by perennial cash flow anxieties in the Treasury.

I was myself talking this morning to a partner in a big 4 accountant who said a few interesting things about the week it’s been.

  1. The most egregious scams, in his opinion, are often designed by lawyers in Dublin and not “invariably” by big 4 to big 6 accountancy companies. Of the three multinational tax avoidance schemes in operation that he himself thought were most legally dodgy only one was down to a big four accountancy company and the other two were cooked up entirely by lawyers.
  2. When I asked whether Matheson were the lawyers he grinned hugely and said absolutely nothing.
  3. When I then asked ‘who is next’ he suggested a well known drug company who strongly considered inverting into Ireland last year and who also have a cash pile in the 10s of Billions of Dollars…and most of this cash pile is NOT in the US today. :slight_smile:

#87

Very interesting 2Pack.

I have had this confirmed to me now by an appropriate source who can opine definitively (first hand). It was (almost) all Apple (part above normal GDP growth). Most aircraft leasing comes with offsetting financing, which means that it’s net effect on GDP is small. Only the IP (and some IP related stuff), add to the GDP (and GNP) without offsetting financing.

There are (at least) two other very large IPs out there (maybe one is your Pharma company, which we can all guess who that long-standing Irish MNC is), what would also distort the Irish national GDP / GNP, but there have been no discussions - to date - with the State (at least on a formal basis), on whether they will “come home” to Ireland.

I would expect that these two IPs got better tax advice on the implications of showing the world that they were using the EU TP system from a “stateless” location (i.e. with no EU tax treaty). It might have given them pause for thought. They might wait for the 130 page report to come out and see how Apple gets on before doing anything else.

Apple is really screwed, and I think the liabilities are only just starting to for it.

When Apple realises how aggressive it’s EU tax advice was, it is going to want to start suing some Dublin advisors.


#88

Sorry to spoil a nice Sunday afternoon by mentioning he who should not be mentioned…

thetimes.co.uk/edition/irela … -c33r330mg


#89

Wow, so official policy it to throw Revenue ‘bad apples’ (snigger) to the wolves…

I guess that provides a political way out?


#90

I am sure Revenue have a thick file on Bertie :astonished:


#91

The Marian Finucane Show this AM- the entire panel were adamant that it’s not our money and that we won’t see a red cent of it. It’s a pure political play by the EU Commission in a veiled attack on the US.

*The Panel: Michael McDowell - Ind. Senator / former Tánaiste & Minister for Justice, Suzanne Kelly - Tax Lawyer, John McGuiness - FF TD for Carlow Kilkenny, Patsy McGarry - Irish Times Religious Affairs Correspondent & Diarmuid Ferriter - Professor of Modern History, UCD. *

Suzanne Kelly was nearly having fits for the 45 minutes this was discussed!
The Panel were into Irexit mode at some staged during the discussion


#92

I am amazed that the studio had the capacity to accommodate the collective egos.

Collective intelligence - probably not an issue judging by the Irexit mode.

Yeah yeah lets tell the EU to fuck off. How smart? And those companies are here because? :unamused:


#93

If you think women can be bad, try scorning a government dept. A1 smart and ballsy move there by Bertie (Another non-accountant :smiley: )


#94

For some reason this submission to Gov from Matheson in 2014 is only available as a cached copy ATM. (My emphasis)


#95

Very interesting backgrounder from 2013 in the WSJ.

Matheson are mentioned numerous times. Without suggesting any wrongdoing at all, I don’t think it’s an unreasonable conclusion that their advice has pissed off people stateside.

wsj.com/articles/SB100014240 … 2697448774

ps google “stateless” and “matheson” and you get 35,000 results (a lot with the line through matheson mind - not quite sure how to do the verbatim search with the totals reported). I was talking to a big firm lawyer during the week who told me they had scrubbed their site for 110 promotions. I laughed and noted Arthur’s Cock seemed to have done the same but they were still in Google’s cache and we laughed :stuck_out_tongue:


#96

Apple v Sausages

bbc.com/news/business-37259278


#97

They also don’t have the grace to be a proper acronym, he added… though MmmmmNIL…?


#98

Dopey cunts think that 60 days = expiry on the Google Cache and they are in the clear. Some of us, however, remember the turd that was called mop.ie for many years. :smiley:

They left stuff like the links below around naming people like Dualta Counihan and Shay Lydon and Ann Marie Bohan in the three entirely RANDOM linked examples below (and neither of whom had anything to do with Apple may I state) …and any one of whom could have a sealed RICO indictment awaiting them next time they fly into New York for all I know…and of COURSE I know that these things don’t happen to Irish Lawyers normally but the big boys are engaged now so who cares about some functionary in Dublin if they will cop a fast plea to avoid a RICO. :smiley:

In the big boy world with tectonic trade block collisions ongoing…nobody cares about a few lawyers in Dublin any more. Too much serious money at stake.

web.archive.org/web/20111021054 … k-2011.pdf
web.archive.org/web/20111021064 … -Lydon.pdf
web.archive.org/web/20111021065 … r20AMB.pdf

But given the amount of shit that Matheson AKA mop.ie have left lying around over the years you only need ONE of their staff to sing…just the one. They then qualify as a ‘co operating’ witness in the US legal scheme of things and that is enough for our American cousins normally. Anyone who thinks otherwise should look up the name “Scott Rothstein” , Scott was never a mobster.

Will I slosh through Arthur Cooks online footprint at random there Grumpy??? Purely at random.


#99

I don’t think there is any need to pick on AC. They were all at it. Chasing the fees.

Apart from Eugene Fanning of course (of AC) with his porn obsession. How would he have time?

independent.ie/irish-news/family-ordeal-is-over-as-lawyer-cleared-of-childporn-charges-26409205.html


#100

Arthur Cox made their website hard to crawl after 2007 or so, unlike Matheson who left it all out there. :slight_smile:

Anyway, here is a bit of advice for our politicians. Did anyone know that the first mention of the AAA was in the book of Genesis same as Adam n Eve??

https://media.licdn.com/mpr/mpr/AAEAAQAAAAAAAAhOAAAAJDJhMjE4NjUwLTA3NjAtNDg4My1iYzYxLTRlMzQ2ZmUyNmE5Ng.jpg