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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 4:42 pm 
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If I hear 1 more FGer say 'we can't be the global tax policemen for Apples profits'.
That cretin Brian hayes on The Last Word now mouthing it off...Pascal O'Donoghue and Richard Bruton had the same spiel over and over again this AM.

It's pure BS...if you allow Apple to book it's Global Revenue's through an office in Dublin, then it gets taxed here. Or thats my simpleton reading of it


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 4:59 pm 
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FreeFallin wrote:
It's pure BS...if you allow Apple to book it's Global Revenue's through an office in Dublin, then it gets taxed here. Or thats my simpleton reading of it


It's what's done now. It's what should have been done then.

Logically the second should follow the first.


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 5:26 pm 
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Another simpleton question

Noonan & FG are repeating that Apple did not get a special deal

Does the EU ruling completely contradict this is (i.e. they're lying) or are they deliberately using semantics to avoid it technically being a lie?

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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 5:47 pm 
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Renting And Proud! wrote:
Another simpleton question

Noonan & FG are repeating that Apple did not get a special deal

Does the EU ruling completely contradict this is (i.e. they're lying) or are they deliberately using semantics to avoid it technically being a lie?

They didn't get a deal from Government (on paper anyway). Revenue allowed them to interpret things in a unique way that was contradictory to the spirit of the law.

That's my understanding.


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 5:55 pm 
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Col. Max Pyatnitski wrote:
Didn't like it much. It struck me at the time even as an example of how low-tech and crappy some "high tech MNC" jobs were and also looked like a bit of a cover-story for tax-avoidance or something (much like the pool-hall I used to play in always seemed too quiet (and too cheap) to be a real business and I always assumed it was money laundering...

Yeah, there's one in Dublin 6 that I always assumed was a front for something for exactly that reason...


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 5:57 pm 
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Madness of Crowds wrote:
NegativeEquity wrote:
Independent Alliance refuses to back FG plan to appeal Apple ruling

http://www.irishtimes.com/news/politics ... -1.2774281


Principled, or just lining up to lobby for shares of the €13B for their constituencies? :nin

Bunch of populists demand populist action shocker.


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 9:43 pm 
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Renting And Proud! wrote:
Another simpleton question

Noonan & FG are repeating that Apple did not get a special deal

Does the EU ruling completely contradict this is (i.e. they're lying) or are they deliberately using semantics to avoid it technically being a lie?


It is a lie at every level. Revenue agreed to calculate their tax based on their expenses rather than their profits. This is unheard of as far as I know.

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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 9:49 pm 
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Why is there even a debate about this? How is the non-existent head office not paying tax because it didn't exist not the screaming headline here? Even the FT barely mentions it, I genuinely dont understand this.


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 10:01 pm 
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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Wed Aug 31, 2016 10:53 pm 
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Mantissa wrote:
Renting And Proud! wrote:
Another simpleton question

Noonan & FG are repeating that Apple did not get a special deal

Does the EU ruling completely contradict this is (i.e. they're lying) or are they deliberately using semantics to avoid it technically being a lie?


It is a lie at every level. Revenue agreed to calculate their tax based on their expenses rather than their profits. This is unheard of as far as I know.

+1
also, look at this post/thread: viewtopic.php?p=889370#p889370

I've listened to various radio emissions (word chosen) today and yesterday on this. It boils down to politicians of the FG hue trotting out the line above, combined with tax-experts from likes of Grant Thornton, PWC, etc., giving a spiel "nothing to see here".

They're not so much telling lies as denying reality. It's Comical Ali territory. However, it's no so comical when you're locked in the asylum with them and outfits like RTE are rowing in behind it too. Brian Hayes was on Right Hook this evening, the very last thing he was going to do was cite elements of the finding that were wrong. I'm sure he hasn't even read it.

What I would so much want the interview to do is go exactly on that line. "What parts do you feel are incorrect, in detail?" "waffle", "do you disagree with point A", etc., "have you read the report Brian", "is it appropriate for you to come on to the national airwaves to express opinion without even reading the finding". Fantasy land of course.

This isn't even about tax avoidance, nor is it about our tax rates. It's about another type of cronyism, it's about yet more regulatory capture, it's about unfairness, it's about not having formal rules and processes, it's about being half-assed and then just trying to lie/distract your way out of this. It's about hoping that folk don't reason and apply logic.

but do read observer35's post linked above... read the finding too and make up your own mind.


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Thu Sep 01, 2016 12:44 am 
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Brian Hayes is a Class "A" fantasist (0:25).... watch the cogs turn when faced with the reality.


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Thu Sep 01, 2016 8:36 am 
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Mantissa wrote:
Renting And Proud! wrote:
Another simpleton question

Noonan & FG are repeating that Apple did not get a special deal

Does the EU ruling completely contradict this is (i.e. they're lying) or are they deliberately using semantics to avoid it technically being a lie?


It is a lie at every level. Revenue agreed to calculate their tax based on their expenses rather than their profits. This is unheard of as far as I know.

Well, no, that's not the way I understand it - I think there are two elements - the stateless corporation (Apple not HQ'd in Ireland, so profits outside Ireland are not taxed in Ireland, but in country of HQ. That there was no HQ, not Ireland's business - that appears to be the main source of Ireland's defence). Second - the whole "what's a profit anyway" thing - this is a much wider issue and is at the heart of the headquartering in Ireland, I think this is what the EU are really after and where the Revenue are on ropey ground.

But I haven't been paying that much attention; my yellow-pack MNC job is keeping me busy :|

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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Thu Sep 01, 2016 9:15 am 
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yoganmahew wrote:
Mantissa wrote:
Renting And Proud! wrote:
Another simpleton question

Noonan & FG are repeating that Apple did not get a special deal

Does the EU ruling completely contradict this is (i.e. they're lying) or are they deliberately using semantics to avoid it technically being a lie?


It is a lie at every level. Revenue agreed to calculate their tax based on their expenses rather than their profits. This is unheard of as far as I know.

Well, no, that's not the way I understand it - I think there are two elements - the stateless corporation (Apple not HQ'd in Ireland, so profits outside Ireland are not taxed in Ireland, but in country of HQ. That there was no HQ, not Ireland's business - that appears to be the main source of Ireland's defence). Second - the whole "what's a profit anyway" thing - this is a much wider issue and is at the heart of the headquartering in Ireland, I think this is what the EU are really after and where the Revenue are on ropey ground.

But I haven't been paying that much attention; my yellow-pack MNC job is keeping me busy :|


Prepare to be amazed:

Quote:
In 1991, a basis for determining Apple Computer Ltd.’s (subsequently AOE’s) Irish branch net profit was proposed by Apple and agreed by Irish Revenue. According to that ruling, the net profit attributable to the AOE branch would be calculated as 65% of operating expenses up to an annual amount of USD [60- 70] million and 20% of operating expenses in excess of USD [60-70] million. This was subject to the proviso that if the overall profit from the Irish operations was less than the figure resulting from this formula, that lower figure would be used for determining net profits.


Quite unprecedented AFAIK.

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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Thu Sep 01, 2016 11:20 am 
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Lets see who was in power in 1991..

Oh, it was Charles Haughey. Enough said?

The Apple deal in 1991 came about because it had a manufacturing plant in Cork and the Apple of the time was a traditional computer company that had yet to been restructured as a pure law breaking, tax evasion corporation. That happened after Jobs stabbed Amelio in the back and fired everyone who was not a yesman or cult member. MS was the pure law breaking tech company back then. The Apple of the time did engage in some interesting tax maneuvers. I'm thinking of the very expensive CPU's in suitcases stories. Plus odd things happened in Singapore. But on the whole it was just another computer hardware company with healthy margins, especially on peripherals. Nothing too creative on the tax front.

Jobs (like Gates) was a criminal psychopath, he believed that laws never applied to him, so Apple was restructured in his image. Thats all you need to know about Apple and how it has operated over the last 20 years. My guess is that the '91 deal was not really used as a major conduit for world income until the 2000's when Apple became a consumer electronics company with unfeasibly large net margins.

There was nothing unusual about the Revenue deal. It happened all the time. If you were a company / entity with high net income and who could relocate your income destination at little cost or disruption then you would get to see the warm cuddly side of Revenue. Where a bunch of the (very) senior guys would turn up to the meeting and would open with "Now what can we do for you? How can we be of help?.." with their most winning smiles.

I'm definitely reaching for the pop corn on this one. With a bit of luck we night even get a RICO out of it. Now that would be fun. Maybe someday the name Jobs will be bracketed with Maxwell as examples of the utterly nasty face of capitalism.


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 Post subject: Re: Will Ireland's corporation tax survive?
PostPosted: Thu Sep 01, 2016 11:24 am 
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jmc wrote:
Lets see who was in power in 1991..

Oh, it was Charles Haughey. Enough said?

And we had three Finance ministers in 1991:

- Albert Reynolds
- Charlie Haughty (acting)
- Bertie Ahern

And then when it was renewed in 2007:

- Brian Cowan

Yep, enough said!

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