What I am suggesting is that there are a number of opinions offered on both sides the debate concerning the EU Commissions ruling on Apple.Is it your opinion that the Commission is non-partisan?
One, he is not my hero. Two, to me the crux of the issue will boil down to, not whether or whether or not Microsoft could afford the same expertise (of course they could) but whether or not Microsoft and others were facilitated by Irish authorities to avoid paying CT tax in this way.bigshort your leftie hero makes some laudable points I'm sure but on the key issue of selectivity he is off the wall. Your own example of Microsoft could surely afford the same expertise as Apple.
Revenue give rulings regarding the tax implications of various company actions. But that does not amount to endorsements of those actions. The commissioner has to explain what she means by endorsement.Perhaps but they could most certainly have a huge influence on Company structures/revenue flows, depending on the tax interpretations provided
Yep, that's my reading of it as well (for what that's worth!).to me the crux of the issue will boil down to, not whether or whether or not Microsoft could afford the same expertise (of course they) but whether or not Microsoft and others were facilitated by Irish authorities to avoid paying CT tax in this way.
If the facility is available to all corporations then fine, its a loophole that needs to be closed, but Apple should not be liable. But if its a facility only available to select corporations, then there is a problem.
I think she means endorsed them as appropriate for tax. Of course Apple are free to allocate all their profits to the coffee machine but Revenue endorsement is about taxable profits and that is within their gift to an extent.Ms V said:The Commission's investigation has shown that the tax rulings issued by Ireland endorsed an artificial internal allocation of profits within Apple Sales International and Apple Operations Europe, which has no factual or economic justification.
Perhaps the Microsoft comparison was a poor one to make. But couldn't any software developer arguably be a competitor of Apple?Bigshort I totally agree with your last assessment but that leftie chap specifically said Apple had an unfair advantage simply coz they can afford expensive lawyers and accountants. Most MNCs have the same capacity so no way does this select Apple.
Where I work we compete against companies which are large enough to have a manufacturing base in China and transfer price back into Europe and then sell here at a lower price than we can offer. That gives them a competitive advantage in that regard but if we were big enough the same option would be open to us. In other words their competitive advantage is not based on government policy but issues outside of that. It's the same with the B&B versus the Hotel or Apple versus the little guy down the road.Similar to how a small b&b is in competition with a large hotel chain. If the large hotel chain can resource the financial expertise to concoct a tax avoidance scheme that meets with Revenue approval then it is a question of whether such a scheme puts them at unfair competitive advantage. The EU Commission is arguing that it does and I would be inclined to agree.
Well the reason there isnt the witch hunt, as you say, is perhaps because the arrangements were not afforded to, or facilitated for, other MNC's despite such companies having the financial clout to devise such schemes? Hence, supporting the Commissions view.Bigshort I see where you are coming from. If Ms V is arguing that Apple and similar MNCs had a selective advantage over Fred in the Shed I think that would be a very difficult case to win, after all the "standard" Double Irish was presumably only available to the few usual suspects. And why is there not now a witch hunt against these other takers of the forbidden Apple.
No, to win, her case will surely have to be that it was much more selective than that.
Maybe, but if so then I don't think we would be objecting so strongly. Let's face it, they aren't here for our self classified "world class education system".Well the reason there isnt the witch hunt, as you say, is perhaps because the arrangements were not afforded to, or facilitated for, other MNC's despite such companies having the financial clout to devise such schemes? Hence, supporting the Commissions view.
But the objections are muddled at best. There is an apparent attack on our sovereignty - this is nonsense.Maybe, but if so then I don't think we would be objecting so strongly. Let's face it, they aren't here for our self classified "world class education system".
This is a fantasy. Time and time again the EU has shown that there is one set of rules for small countries, and one for larger countries. Anyone who thinks Ireland can be a friend of Germany or France must have been living in a different universe for the last 10 years...Colette Browne's piece is excellent. Yes we should appeal, I think. But this indignant outrage at an attack on our sovereignty is a very dangerous game. I really can't buy into the paranoia narrative. We have been getting it very easy indeed from the EU and that includes the bail out from our reckless folly. We need a reality check here, now is the time to make friends and influence our EU partners, not the time to behave as spoiled brats.
You mean whatever treatment is meted out to an EU member state, if the member state doesn't leave, it must be alright and fair and legitimate treatment and beyond criticism? Even if it means one set of rules for big countries, and one set of rules for small nations? Really?odyssey66 ever hear of Article 50? Membership of the EU is entirely voluntary. Strange that even today after all these terrible beatings up by our French/German masters there is not a whisper for Irexit. Same goes for Portugal. And as for Greece, despite the invocations of WWII massacres, the last thing the populace wanted was to be kicked out of this club, supposedly run by their German oppressors.
I understand the sense of cold turkey. Having gotten hooked on bemoaning 800 years of victimisation by our nearest neighbour we badly need a replacement.
But let's get very real here. The EU has been and still is for Ireland "le poule aux oeufs d'or".