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The earliest recorded versions of the Double Irish-type BEPS tools are by Apple in the late 1980s, [19] and the EU discovered Irish Revenue tax rulings on the Double Irish for Apple in 1991. [12] Irish state documents released to the Irish national archives in December 2018 showed that Fine Gael ministers in 1984 sought legal advice on how U.S ...
The U.S. administration condemned Apple's Irish tax structures in the 2013 Levin–McCain PSI, [59] [60] [61] however, it came to Apple's defense when the EU Commission levied a €13 billion fine on Apple for Irish tax avoidance from 2004 to 2014, the largest corporate tax fine in history, arguing that Apple paying the full 12.5% Irish ...
Double Irish arrangements have allowed multinational companies to avoid taxes owed to countries in which foreign subsidiaries of a U.S.-based multinational corporation are incorporated. Repatriation tax avoidance strategies, however, have allowed U.S.-domiciled companies to avoid owing taxes to the United States.
Apple lost a long-running court battle with the European Union on Tuesday, resulting in the company being forced to pay 13 billion euros ($14.4 billion) in back taxes to Ireland, as part of a ...
The Double Irish was the largest BEPS tool in history which by 2015, was shielding over US$100 billion in mostly US corporate profits from US taxation. When the EU Commission fined Apple €13 billion for using an illegal hybrid-Double Irish structure, their report noted that Apple had been using the structure from at least as far back as 1991 ...
The Irish tax code considers IRL2 a Bermuda company (used the "managed and controlled" test), but the US tax code considers IRL2 an Irish company (uses the registration test). Neither taxes it. Apple's subsidiary, ASI, behaved like it was IRL2, it was "managed and controlled" via ASI Board meetings in Bermuda, so Irish Revenue did not tax it.
The second tax evasion investigation started in 2021 and was triggered by routine checks carried out by tax police in an area north of Milan, the two sources with knowledge of the matter said.
The aim of the project is to mitigate tax code loopholes and country-to-country inconsistencies so that corporations cannot shift profits from a country with a high corporate tax rate to countries with a low tax rate. The practice - in particular double non-taxation - is usually legal but often involves complex manoeuvres within tax law.