Yang, James G. S.
Apple's tax debacle in Ireland / James G.S. Yang and Leonard J. Lauricella .-- , 2017
Disponible también en línea a través de la Biblioteca del Instituto de Estudios Fiscales. Resumen. Conclusión.
On August 30, 2016, the European Commission (the Commission) concluded that Apple Inc. had been granted tax benefits by Ireland that gave it a competitive advantage over other businesses. The Commission claimed that this was aviolation of European Union (E.U.) state aid rules, and the government of Ireland was ordered to collect from Apple up to .13 billion plus interest (approximately $14.3 billion) representing an underpayment of tax for the period from 2003 until 2014. The crux of the Commission.s argument was the impact of two rulings by Ireland that had the effect of allowing Apple to earn large amounts of incomein Europe that was not subject to tax in any jurisdiction. This was deemed to be a violation of the principle that a state has the right to tax income earned within its jurisdiction measured under an arm.s-length principle. The authors describe Apple's operations in Europe and how it was able to achieve such tax favorable results. They then discuss the Commission.s attack on Apple's structure, and Apple's potential defense.
EMPRESAS MULTINACIONALES
IMPUESTOS
GASTOS FISCALES
AYUDA ESTATAL
INCUMPLIMIENTO DEL DERECHO COMUNITARIO
TAX RULINGS
IRLANDA
UNION EUROPEA
Lauricella, Leonard J.
Journal of Taxation of Investmentsv. 34, n. 3, Spring 2017, p. 15-28
Apple's tax debacle in Ireland / James G.S. Yang and Leonard J. Lauricella .-- , 2017
Disponible también en línea a través de la Biblioteca del Instituto de Estudios Fiscales. Resumen. Conclusión.
On August 30, 2016, the European Commission (the Commission) concluded that Apple Inc. had been granted tax benefits by Ireland that gave it a competitive advantage over other businesses. The Commission claimed that this was aviolation of European Union (E.U.) state aid rules, and the government of Ireland was ordered to collect from Apple up to .13 billion plus interest (approximately $14.3 billion) representing an underpayment of tax for the period from 2003 until 2014. The crux of the Commission.s argument was the impact of two rulings by Ireland that had the effect of allowing Apple to earn large amounts of incomein Europe that was not subject to tax in any jurisdiction. This was deemed to be a violation of the principle that a state has the right to tax income earned within its jurisdiction measured under an arm.s-length principle. The authors describe Apple's operations in Europe and how it was able to achieve such tax favorable results. They then discuss the Commission.s attack on Apple's structure, and Apple's potential defense.
EMPRESAS MULTINACIONALES
IMPUESTOS
GASTOS FISCALES
AYUDA ESTATAL
INCUMPLIMIENTO DEL DERECHO COMUNITARIO
TAX RULINGS
IRLANDA
UNION EUROPEA
Lauricella, Leonard J.
Journal of Taxation of Investmentsv. 34, n. 3, Spring 2017, p. 15-28