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PDF The General Court of the European Union annuls the decision

International (ASI) and Apple Operations Europe (AOE) which were companies incorporated in Ireland but not tax resident in Ireland The contested tax rulings endorsed the methods used by ASI and AOE to determine their chargeable profits in Ireland relating to the trading activity of their respective Irish branches

  • Are Apple Sales International & Apple Operations Europe incorporated in Ireland?

    In 2016 the Commission adopted a decision2 concerning two tax rulings issued by the Irish tax authorities (Irish Revenue) on 29 January 1991 and 23 May 2007 in favour of Apple Sales International (ASI) and Apple Operations Europe (AOE), which were companies incorporated in Ireland but not tax resident in Ireland.

  • When did Apple start making money in Ireland?

    1980 – Apple establishes production facilities in Cork, Ireland. 1991 – Irish State agreed the first tax deal with Apple Inc (one of the two rulings cited by the EU Commission). 2007 – Original 1991 tax agreement is re-negotiated with Irish State (the second ruling cited by the EU Commission).

  • How many subsidiaries does Apple have in Ireland?

    Apple's Offshore Organisational Structure (2013 Senate Report) In 2014, Apple's Irish structure consisted of two subsidiaries; Apple Operations Ireland ("AOI") an Irish-registered holding company which acts as an internal financing company.

  • Did Ireland have a 'right not to know' about Apple tax planning?

    At a tax conference in 2023, Helena Malikova put forward the idea that Ireland and other States had decided not to gather relevant information on tax planning schemes, including on the Apple tax planning scheme. Malikova described this approach to tax matters as a sovereign “right not to know”.

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