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Ireland to close Apple tax loophole

Ireland says it plans to shut down a much-criticised tax arrangement used by Apple Inc to shelter over $40 billion from taxation.

But, Reuters reports, it will leave open an even bigger loophole that means Apple is unlikely to pay any more tax.

Ireland said it was to act to protect its reputation on the issue of global tax avoidance and would publish legislation to ensure Irish registered companies could not remain “stateless” in terms of their tax residency.

A US Senate committee investigation revealed in May that Apple had cut billions from its tax bill by declaring companies registered in the Irish city of Cork as not tax resident in any country. Senator Carl Levin said the company had achieved the “holy grail of tax avoidance” with the structures.

Irish leaders protested angrily against the committee's characterisation of Ireland as a facilitator of tax avoidance.

Parliamentary hearings were subsequently held to review Ireland's tax rules amid concerns that damage to its reputation could jeopardise the foreign investment on which its economy relies heavily, Reuters reported.

Irish Finance Minister Michael Noonan said on Tuesday that he planned to make it illegal for a company registered in Ireland to have no tax domicile anywhere.

He added that companies could still nominate any country they liked as their tax residence, including zero tax jurisdictions such as Bermuda — a provision that tax advisers said was unusual internationally.

Companies such as Google and Microsoft have cut their overseas tax rates to single digits by establishing Dublin-registered subsidiaries, which they have designated as tax resident in Bermuda.

Reuters noted that “Google and Apple have Irish-registered and tax resident subsidiaries that make sales to customers. These then pay large, tax-deductible sums of money in royalties to their Bermuda tax-resident affiliates, ensuring that profits are channelled to the zero-tax jurisdiction.”

The arrangement has become known in the tax avoidance industry as the “double Irish”.

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Published October 16, 2013 at 9:00 am (Updated October 15, 2013 at 7:19 pm)

Ireland to close Apple tax loophole

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