独家
里面的故事,苹果的140亿美元的税款
参议院启示非议Maxforce办公室的名字塔,1960年代高层在布鲁塞尔的破旧Saint-Josse附近。
-
WhatsApp新特性允许在Android上传输数据
WABetaInfo表示,该公司将给未来带来新功能更新的应用程序在开发阶段。有了这个特性,用户可以聊天记录转移到一个新的设备通过扫描二维码。
-
-
-
你会认为它可能获得名称通过应用最大力量在调查所谓的金融骗局。它没有。它只是由一个叫马克斯。
欧洲委员会官员给了工作组的绰号税收筹划实践为其首席,马克斯Lienemeyer,一个瘦长的,悠闲的德国律师声名鹊起的审查计划支撑陷入困境的银行在欧洲的债务危机。
Lienemeyer的团队15国际公务员追求一项为期三年的调查从欧盟委员会(European Commission)的走廊,欧盟的执行机构,爱尔兰财政部和苹果的总部位于加州,加州。
这里概述了第一次,这个故事记录之间的冲突越来越大欧洲和美国和欧盟的转变方法跨国公司的税务。
Maxforce认为爱尔兰允许苹果创建无状态实体有效地让它决定多少钱或多少税收支付。研究人员表示,该公司的利润来自几十个国家通过两个爱尔兰的单位。
至少在一个系统默认支持爱尔兰当局,收益分割,绝大多数归因于“总部”,没有员工,没有特定的基地,因此容易从爱尔兰以外的销售没有任何利润征税。与此同时,美国没有税务单位,因为他们包含在爱尔兰。
欧盟表示8月爱尔兰违反欧洲法律给苹果一个甜心交易。它下令国家法案iPhone制造商创纪录的130亿欧元(合139亿美元)的税款,加上利息,从2003年到2014年。
委员会引用了一个例子:2011年,一个单位被称为苹果销售国际记录从欧洲销售约160亿欧元的利润。但只有5000万欧元被视为应税在爱尔兰,造成了159.5亿欧元的利润征税,该委员会说。
欧盟表示,它的目标是“确保平等待遇的公司”在欧洲,苹果认为,欧盟委员会有选择地目标公司。
裁决,欧盟“追溯改变规则,选择忽略几十年的爱尔兰法律,”及其调查人员不了解欧洲和美国税收制度之间的差异,苹果在12月8日的一项声明中说。
苹果,约6000名工人在爱尔兰,爱尔兰表示,其单位母公司支付许可费用在其产品中使用的知识产权。爱尔兰的公司没有自己的知识产权,所以他们不欠的税在爱尔兰,苹果说,但是单位将面临遣返利润时美国税款。“这个案子从未苹果付多少税,而是我们的税收支付,”该公司表示。“我们缴税我们赢得的一切。”
爱尔兰11月9日呼吁欧盟委员会的裁决在普通法院在卢森堡,认为这给了苹果没有特殊待遇。
爱尔兰财政部长Michael Noonan曾表示,他“非常不同意”与执政党爱尔兰严格遵循税收法规。爱尔兰政府称无权非居民企业税收利润来自国外的活动。
“看看小打印”在iPhone上,努南后表示,欧盟发布了执政的8月。“加州设计,中国制造的。这意味着任何应计利润没有积累在爱尔兰,所以我看不出为什么纳税义务在爱尔兰。”
在未来的几周内,欧盟预计将发布Maxforce调查的细节。大约在同一时间,苹果可能会提出自己的在欧盟法庭提起上诉。虽然苹果公司将不得不在数周内支付税款,这笔钱将在托管,可能需要数年时间来解决问题。
这个故事是根据采访数十名来自欧盟的官员,爱尔兰,和苹果,尽管大多数不想讲税收记录讨论敏感问题。
拒绝让Lienemeyer Maxforce代表接受采访。爱尔兰的收入专员办公室(相当于美国国税局(Internal Revenue Service)说,它不能对特定公司发表评论。
“矛盾和歧义”蒂姆·库克在欧盟的调查。
Lienemeyer开始组装Maxforce 2013年春末的授权审查税收政策在欧洲寻找任何偏袒。直接补贴或税收优惠,以法院的一个特定的公司在欧盟是非法的,以防止政府协助国家冠军企业。
他第一次雇佣——监督苹果调查的人是海伦娜Malikova,一位曾在斯洛伐克瑞士信贷(Credit Suisse)在苏黎世集团。他很快补充说,卡米拉Kaukiel波兰金融分析师曾在毕马威(KPMG)和Saskia•亨,前荷兰政府的税收政策顾问。
作为四个初始成员开始了他们的调查,他们有了一个好的开始从美国参议院调查美国跨国公司的税务策略。参议院常务调查委员会表示,苹果数百亿美元的利润转移到基于无状态的分支机构在爱尔兰,在那里获得不到2%的税率。
在2013年5月21日上午9:30,参议员们聚集在德克森办公大楼106室。包含在证据这一天是2004年汤姆·康纳的来信官员爱尔兰的税务机关,安永(Ernst & Young),苹果公司的税务顾问。
康纳的问题:一个单位的科技公司没有提交纳税申报表;它仍然在业务?安永回应两天后,划分非居民控股公司没有真正的销售。“没有返回公司所得税的角度来看,”安永写道。参议院展品不包括康纳可是一项的反应。
在听证会上,亚利桑那州共和党人麦凯恩谴责苹果“美国最大的避税者之一。”
民主党人卡尔•莱文密歇根在眼镜栖息在他的鼻尖,说苹果使用“离岸避税策略,其目的是避税,纯粹而简单的。”
至关重要的是,然而,莱文告诉拥挤的房间里,根据美国法律,几乎没有面板可以迫使苹果公司支付更多的税。苹果公司首席执行长库克(Tim Cook)热情捍卫公司的行动,告诉参议员们“我们不依赖于税收噱头。”
参议院启示非议Maxforce办公室的名字塔,1960年代高层在布鲁塞尔的破旧Saint-Josse附近。三周后的参议院听证会上,Lienemeyer的团队要求爱尔兰苹果公司的纳税情况的细节。
爱尔兰税务当局很快派出一位代表携带公文包装满一束绑定页面。
爱尔兰可以简单的材料通过电子邮件发送,但他们谨慎分享与欧盟和纳税人的信息有一个基本原则,以避免泄漏:从来没有发送这些文档电子化。
虽然爱尔兰政府仍然看涨的公开声明,称苹果公司没有得到任何好处,在幕后紧张局势上升。在2013年的夏天,财政部向政府部长,欧盟调查将等于零,据知情人士透露。
但这些断言似乎比之前的沟通缺乏自信。有一个感觉,苹果曾爱尔兰税务地位在一个完全不同的时代,没有人记得几十年前许多谈判的细节。
1980年,4岁的公司——苹果III桌面刚刚发布了几爱尔兰子公司,每一个都有不同的功能,如生产或销售,根据参议院的报告。爱尔兰法律规定可以追溯到1950年代用来支撑濒临崩溃的战后经济,作为一个所谓的出口公司苹果在海外销售的产品没有缴纳任何税款在爱尔兰。
符合欧洲法规,爱尔兰终于结束了1990年零税务政策。之后,苹果和爱尔兰同意利润归因于一个关键爱尔兰单位,汤姆·康纳的信中讨论的部门被限制使用一个复杂的公式,在1990年将导致应税利润3000万美元至4000万美元。
苹果税务顾问“承认没有科学依据”这些数字,但数量会”这样的大小,他希望这将被视为一个善意的建议,“根据笔记从1990年会见爱尔兰税务机关援引欧盟。方程并没有改变,即使苹果开始组装的大部分产品在亚洲。
爱尔兰和苹果开始做出改变后几个月Maxforce开始调查他们的税收关系。2013年10月,财政部长努南宣布他将关闭漏洞,让无状态的控股公司经营的爱尔兰。欧盟说,苹果改变了2015年爱尔兰的结构单位。
随着Maxforce加紧调查2014年6月,爱尔兰总理Enda Kenny在加州是吸引潜在投资者。在旧金山的活动促进爱尔兰企业家,州长杰里。布朗打趣说,他认为苹果“加州公司,”但是根据纳税申报表,“他们真的爱尔兰公司。”News clips show Irish officials looking on stony-faced as the governor makes his jest.
执行欧盟规则税收是一种“公平”欧盟竞争首席,Margrethe Vestager
Lienemeyer的团队深入挖掘问题,苹果的担忧加深。2016年1月,首席执行官库克会见Margrethe Vestager,欧盟竞争首席,Lienemeyer终极老板——10层的贝尔蒙特大楼,机构总部在布鲁塞尔的欧洲委员会。
维斯塔,两个路德教牧师的女儿,有一个公平的名声但艰难,削减失业救济金而提倡严格的新规则对银行当她担任丹麦的财政部长。
虽然她也承认,她的团队没有经验与税务裁决——11月法国社会杂志采访时,她说,“我们在工作中学习”——维斯说税收执行欧盟规则是一种“公平”。
在与库克会面她询问他在全球不同地区苹果支付的税收。她告诉苹果高管,“有人对你征税,”据一位出席了会议。
在1月25日彭博社后续信获得,库克感谢维斯塔“坦诚、建设性的交换意见,”,重申,苹果的收益“受递延税收在美国,直到这些利润汇回。”
随后的通信变得更加激烈。3月14日,库克写信给维斯,他担心这些诉讼的公平。”The Commission had failed to explain fully the basis on which Apple was being investigated, and the body's approach was characterized by "inconsistency and ambiguity," Cook said.
苹果声称,欧盟取消了一项2014年决定认识到它的两个爱尔兰子公司在技术上没有居住在爱尔兰,因此只承担税利润来自爱尔兰的来源。
现在,库克说,委员会似乎是有意“实施大规模,追溯征税苹果将爱尔兰分公司所有苹果的全球利润以外的美洲。”
“没有矛盾,”欧盟发言人在12月15日的一份声明中说。只有一小部分子公司的利润征税在爱尔兰,声明说。”因此,税务裁决使苹果支付税收大幅低于其他公司,这是非法的在欧盟国家援助规则。”
库克的请求并没有动摇维斯,她打电话给努南8月告诉他结果Maxforce调查:欧盟委员会对爱尔兰的裁决。下午晚些时候,8月29日,爱尔兰官员开始对记者暗示苹果的税款达数十亿美元,“可能是任何东西。”
第二天中午,维斯告诉包装新闻发布会在布鲁塞尔,欧盟委员会已经决定苹果欠爱尔兰130亿欧元。
虽然这相当于2015年国家预算的26%,爱尔兰不想意外,说这项裁决是有缺陷的,因为国家没有给苹果任何特殊待遇。
的决定引发了一场政治危机,左倾Enda Kenny脆弱的少数派政府的成员看到纳税人的巨大潜力,世界上最富有的公司很可能负担得起。
尽管Noonan参观了电视演播室誓言要上诉的决定,独立议员要求爱尔兰取钱。
面临着潜在的起义,推翻政府,肯尼和努南最终屈服于要求审查该国的企业税收制度。但他们说他们将严厉打击,9月7日,爱尔兰国会压倒性地支持上诉的运动。
Lienemeyer的团队和其他欧盟办事处官员说他们已经收集税收约300家公司的信息,寻找他们认为被欧洲各国政府优惠待遇。
当他们不期望所有的收益回报一样沉重,从调查爱尔兰和苹果,他们说一个令人担忧的数字要求的最大力量Maxforce可以应用。
“我们关注的是离群值,你看着东西雷达屏幕上,“Lienemeyer的老板,50岁的荷兰人Gert-Jan•库普曼,负责在欧盟国家援助的执行,在11月在布鲁塞尔举行的发布会上说。“如果你支付大量的税然后是绝对没有什么可担心的。”
![\"](\"https:\/\/st.etb2bimg.com\/Themes\/Release\/images\/responsive\/ettelecom-default.jpg\")
You\u2019d think it might have earned the name by applying maximum force while investigating alleged financial shenanigans. It didn\u2019t. It\u2019s just led by a guy named Max.
A European Commission official gave the nickname to the Task Force on Tax Planning Practices in honor of its chief, Max Lienemeyer<\/a>, a lanky, laid-back German attorney who rose to prominence vetting plans to shore up struggling banks during Europe\u2019s debt crisis.
<\/div><\/div>Since its launch in 2013, the Maxforce has looked at the tax status of hundreds of companies across Europe, including a deal Starbucks Corp<\/a>. had in the Netherlands, Fiat Chrysler Automobiles NV's agreement with Luxembourg, and -- its largest case -- Apple in Ireland.
Lienemeyer\u2019s team of 15 international civil servants pursued a three-year investigation stretching from the corridors of the European Commission, the EU\u2019s executive arm, to Ireland's Finance Ministry and on to Apple's leafy headquarters in Cupertino, California.
Much of it outlined for the first time here, this story chronicles a growing clash between Europe and the US and a shift in the EU\u2019s approach to the tax affairs of multinationals.
The Maxforce concluded that Ireland allowed Apple to create stateless entities that effectively let it decide how much -- or how little -- tax it pays. The investigators say the company channeled profits from dozens of countries through two Ireland-based units.
In a system at least tacitly endorsed by Irish authorities, earnings were split, with the vast majority attributed to a \"head office\" with no employees and no specific home base -- and therefore liable to no tax on any profits from sales outside Ireland. The US, meanwhile, didn't tax the units because they\u2019re incorporated in Ireland.
Lienemeyer\u2019s team of 15 international civil servants pursued a three-year investigation stretching from the corridors of the European Commission, the EU\u2019s executive arm, to Ireland's Finance Ministry and on to Apple's leafy headquarters in Cupertino, California.
Much of it outlined for the first time here, this story chronicles a growing clash between Europe and the US and a shift in the EU\u2019s approach to the tax affairs of multinationals.
The Maxforce concluded that Ireland allowed Apple to create stateless entities that effectively let it decide how much -- or how little -- tax it pays. The investigators say the company channeled profits from dozens of countries through two Ireland-based units.
In a system at least tacitly endorsed by Irish authorities, earnings were split, with the vast majority attributed to a \"head office\" with no employees and no specific home base -- and therefore liable to no tax on any profits from sales outside Ireland. The US, meanwhile, didn't tax the units because they\u2019re incorporated in Ireland.
<\/div><\/div>\"I can\u2019t see why the tax liability is in Ireland.\" \u2014Irish Finance Minister<\/a>, Michael Noonan
In August the EU said Ireland had broken European law by giving Apple a sweetheart deal. It ordered the country to bill the iPhone maker a record 13 billion euros ($13.9 billion) in back taxes, plus interest, from 2003 to 2014.
One example the Commission cites: In 2011, a unit called Apple Sales International recorded profits of about 16 billion euros from sales across Europe. But only 50 million euros were considered taxable in Ireland, leaving 15.95 billion euros of profit untaxed, the Commission says.
Though the EU says its goal is \"to ensure equal treatment of companies\" across Europe, Apple maintains that the Commission selectively targeted the company.
With the ruling, the EU is \"retroactively changing the rules and choosing to disregard decades of Irish law,\" and its investigators don\u2019t understand the differences between European and US tax systems, Apple said in a Dec. 8 statement.
Apple, which has some 6,000 workers in Ireland, says its Irish units paid the parent company a licensing fee to use the intellectual property in its products. The Irish companies didn't own the IP, so they don\u2019t owe tax on it in Ireland, Apple says, but the units will face a US tax bill when they repatriate the profits. \"This case has never been about how much tax Apple pays, it\u2019s about where our tax is paid,\" the company said. \"We pay tax on everything we earn.\"
Ireland on Nov. 9 appealed the Commission\u2019s ruling at the EU General Court in Luxembourg, arguing it has given Apple no special treatment.
Irish Finance Minister Michael Noonan has said he \"profoundly disagrees\" with the ruling and that Ireland strictly adheres to tax regulations. The government says Ireland has no right to tax non-resident companies for profits that come from activities outside the country.
\"Look at the small print\" on an iPhone, Noonan said after the EU released its ruling in August. \"It says designed in California, manufactured in China. That means any profits that accrued didn\u2019t accrue in Ireland, so I can\u2019t see why the tax liability is in Ireland.\"
In the coming weeks, the EU is expected to publish details of the Maxforce investigation. At about the same time, Apple will likely lodge its own appeal in the EU court. Though Apple will have to pay its tax bill within weeks, the money will be held in escrow, and the issue will probably take years to be resolved.
This story is based on interviews with dozens of officials from the EU, Ireland, and Apple, though most didn't want to speak on the record discussing sensitive tax matters.
A Maxforce representative declined to make Lienemeyer available for an interview. Ireland's Office of Revenue Commissioners (the equivalent of the American Internal Revenue Service) says it can\u2019t comment on specific companies.
\"Inconsistency and ambiguity\" \u2014Tim Cook on the EU investigation.
Lienemeyer began assembling the Maxforce in late spring of 2013 with a mandate of scrutinizing tax policies across Europe in search of any favoritism. Direct subsidies or tax breaks to court a specific company are illegal in the EU to prevent governments aiding national champions.
His first hire -- the person who would oversee the Apple probe -- was Helena Malikova, a Slovak who had worked at Credit Suisse<\/a> Group AG in Zurich. He quickly added Kamila Kaukiel, a Polish financial analyst who had been at KPMG, and Saskia Hendriks, a former tax policy adviser to the Dutch government.
As the four initial members began their investigations, they got a head start from a US Senate probe of the tax strategies of American multinationals. The Senate\u2019s Permanent Subcommittee on Investigations said Apple shifted tens of billions of dollars in profit into stateless affiliates based in Ireland, where it secured a tax rate of less than 2 per cent.
At 9:30 a.m. on May 21, 2013, senators gathered in Room 106 of the Dirksen Office Building. Included in the evidence presented that day was a 2004 letter from Tom Connor, an official at Ireland\u2019s tax authority, to Ernst & Young, Apple\u2019s tax adviser.
Connor\u2019s question: A unit of the tech company hadn\u2019t filed a tax return; Was it still in business? E&Y responded two days later that the division was a non-resident holding company with no real sales. \"There is nothing to return from the corporation tax standpoint,\" E&Y wrote. The Senate exhibits didn\u2019t include Connor\u2019s response if there ever was one.
At the hearing, Arizona Republican John McCain castigated Apple as \"one of the biggest tax avoiders in America.\"
Democrat Carl Levin<\/a> of Michigan peered over the glasses perched on the tip of his nose and said Apple uses \"offshore tax strategies whose purpose is tax avoidance, pure and simple.\"
Crucially, though, Levin told the crowded room that under US law, there was little the panel could do to force Apple to pay more tax. Apple Chief Executive Officer Tim Cook passionately defended the company\u2019s actions, telling the senators \"We don\u2019t depend on tax gimmicks.\"
The Senate revelations raised eyebrows at the Maxforce\u2019s office in Madou Tower, a 1960s high-rise in the rundown Saint-Josse neighborhood of Brussels. Three weeks after the Senate hearing, Lienemeyer's team asked Ireland for details of Apple's tax situation.
The Irish tax authorities soon dispatched a representative carrying a briefcase filled with a bundle of bound pages.
The Irish could have simply sent the material via e-mail, but they were cautious about sharing taxpayer\u2019s information with the EU and have a ground rule to avoid leaks: never send such documents electronically.
While the Irish government remained bullish in its public statements, saying Apple hadn\u2019t received any favors, behind the scenes tensions were rising. Through the summer of 2013, the Finance Ministry assured government ministers that the EU investigation would amount to nothing, according to people familiar with the discussions.
But those assertions seemed less confident than earlier communications. There was a sense that Apple had worked out its Irish tax position in a vastly different era, and no one remembered many details of the negotiations decades earlier.
In 1980, the four-year-old company -- the Apple III desktop had just been released -- created several Irish affiliates, each with a different function such as manufacturing or sales, according to the Senate report. Under Irish laws dating to the 1950s designed to shore up the moribund post-war economy, as a so-called export company Apple paid no taxes on overseas sales of products made in Ireland.
To comply with European rules, Ireland finally ended its zero-tax policy in 1990. After that, Apple and Ireland agreed that the profit attributed to a key Ireland-based unit, the division discussed in Tom Connor\u2019s letter, be capped using a complex formula that in 1990 would have resulted in a taxable profit of $30 million to $40 million.
An Apple tax adviser \"confessed there was no scientific basis\" for those figures, but that the amounts would be \"of such magnitude that he hoped it would be seen as a bona-fide proposal,\" according to notes from a 1990 meeting with the Irish tax authority cited by the EU. The equation didn\u2019t change even as Apple began assembling the bulk of its products in Asia.
Ireland and Apple started to make changes a few months after the Maxforce began looking into their tax relationship. In October 2013, Finance Minister Noonan announced he would close the loophole that let stateless holding companies operate out of Ireland. And the EU says Apple changed the structure of its Irish units in 2015.
As the Maxforce stepped up its probe in June 2014, Irish Prime Minister Enda Kenny<\/a> was wooing potential investors in California. At a San Francisco event to promote Irish entrepreneurs, Governor Jerry Brown quipped that he had thought Apple \"was a California company,\" but according to tax returns, \"they\u2019re really an Irish company.\" News clips show Irish officials looking on stony-faced as the governor makes his jest.
Enforcement of EU rules on taxation is a matter of \"fairness\" \u2014EU competition chief, Margrethe Vestager
With Lienemeyer\u2019s team digging further into the issue, Apple\u2019s concern deepened. In January 2016, CEO Cook met with Margrethe Vestager, the EU competition chief -- and Lienemeyer's ultimate boss -- on the 10th-floor of the Berlaymont building, the institutional headquarters of the European Commission in Brussels.
Vestager, a daughter of two Lutheran pastors, has a reputation for being even-handed but tough, cutting unemployment benefits while advocating strict new rules for banks when she served as Denmark's finance minister.
While she has acknowledged that her team had little experience with tax rulings -- in a November interview with France's Society magazine, she said, \"We learned on the job\" -- Vestager says enforcement of EU rules on taxation is a matter of \"fairness.\"
In the meeting with Cook she quizzed him on the tax Apple paid in various jurisdictions worldwide. She told the Apple executives that \"someone has to tax you,\" according to a person present at the meeting.
In a Jan. 25 follow-up letter obtained by Bloomberg, Cook thanked Vestager for a \"candid and constructive exchange of views,\" and reasserted that Apple\u2019s earnings are \"subject to deferred taxation in the US until those profits are repatriated.\"
Subsequent correspondence became more heated. On March 14, Cook wrote to Vestager that he had \"concerns about the fairness of these proceedings.\" The Commission had failed to explain fully the basis on which Apple was being investigated, and the body's approach was characterized by \"inconsistency and ambiguity,\" Cook said.
Apple contended that the EU had backtracked on a 2014 decision recognizing that its two Irish subsidiaries were not technically resident in Ireland, and therefore only liable for taxes on profits derived from Irish sources.
Now, Cook said, it seemed the Commission was intent on \"imposing a massive, retroactive tax on Apple by attributing to the Irish branches all of Apple\u2019s global profits outside the Americas.\"
\"There is no inconsistency,\" an EU spokesman said in a Dec. 15 statement. Only a fraction of the profits of the subsidiaries were taxed in Ireland, the statement said. \"As a result, the tax rulings enabled Apple to pay substantially less tax than other companies, which is illegal under EU state aid rules.\"
Cook's entreaties did little to sway Vestager, and in August she phoned Noonan to tell him the results of the Maxforce investigation: The Commission was going to rule against Ireland. Late in the afternoon of Aug. 29, Irish officials began hinting to reporters that Apple\u2019s tax bill amounted to billions and \"could be anything.\"
At noon the following day, Vestager told a packed press conference in Brussels that the Commission had decided Apple owed Ireland 13 billion euros.
Though that would be equivalent to 26 percent of the 2015 national budget, Ireland didn't want the windfall, saying the ruling was flawed because the country hadn\u2019t given Apple any special treatment.
The decision sparked a political crisis as left-leaning members of Enda Kenny\u2019s fragile minority administration saw a potential bonanza for taxpayers that the world\u2019s richest company could well afford.
Even as Noonan toured television studios vowing to appeal the decision, independent lawmakers demanded that Ireland take the money.
Facing a potential revolt that could bring down the government, Kenny and Noonan eventually bowed to demands for a review of the country\u2019s corporate tax system. But they said they would fight the case, and on Sept. 7, Irish lawmakers overwhelmingly backed the motion for an appeal.
Officials from Lienemeyer\u2019s team and other EU offices say they have gathered tax information on about 300 companies, looking for what they deem to be favorable treatment by governments across Europe.
While they don't expect all of those to yield payoffs as hefty as that from their investigation of Ireland and Apple, they say a worrying number require the kind of maximum force that the Maxforce can apply.
\"We focus on outliers where you're looking at something that is off the radar screen,\" Lienemeyer's boss, 50-year-old Dutchman Gert-Jan Koopman, who is in charge of state-aid enforcement at the EU, said at a Brussels conference in November. \"If you're paying a fair amount of tax then there is absolutely nothing to worry about.\" <\/div><\/div>
In August the EU said Ireland had broken European law by giving Apple a sweetheart deal. It ordered the country to bill the iPhone maker a record 13 billion euros ($13.9 billion) in back taxes, plus interest, from 2003 to 2014.
One example the Commission cites: In 2011, a unit called Apple Sales International recorded profits of about 16 billion euros from sales across Europe. But only 50 million euros were considered taxable in Ireland, leaving 15.95 billion euros of profit untaxed, the Commission says.
Though the EU says its goal is \"to ensure equal treatment of companies\" across Europe, Apple maintains that the Commission selectively targeted the company.
With the ruling, the EU is \"retroactively changing the rules and choosing to disregard decades of Irish law,\" and its investigators don\u2019t understand the differences between European and US tax systems, Apple said in a Dec. 8 statement.
Apple, which has some 6,000 workers in Ireland, says its Irish units paid the parent company a licensing fee to use the intellectual property in its products. The Irish companies didn't own the IP, so they don\u2019t owe tax on it in Ireland, Apple says, but the units will face a US tax bill when they repatriate the profits. \"This case has never been about how much tax Apple pays, it\u2019s about where our tax is paid,\" the company said. \"We pay tax on everything we earn.\"
Ireland on Nov. 9 appealed the Commission\u2019s ruling at the EU General Court in Luxembourg, arguing it has given Apple no special treatment.
Irish Finance Minister Michael Noonan has said he \"profoundly disagrees\" with the ruling and that Ireland strictly adheres to tax regulations. The government says Ireland has no right to tax non-resident companies for profits that come from activities outside the country.
\"Look at the small print\" on an iPhone, Noonan said after the EU released its ruling in August. \"It says designed in California, manufactured in China. That means any profits that accrued didn\u2019t accrue in Ireland, so I can\u2019t see why the tax liability is in Ireland.\"
In the coming weeks, the EU is expected to publish details of the Maxforce investigation. At about the same time, Apple will likely lodge its own appeal in the EU court. Though Apple will have to pay its tax bill within weeks, the money will be held in escrow, and the issue will probably take years to be resolved.
This story is based on interviews with dozens of officials from the EU, Ireland, and Apple, though most didn't want to speak on the record discussing sensitive tax matters.
A Maxforce representative declined to make Lienemeyer available for an interview. Ireland's Office of Revenue Commissioners (the equivalent of the American Internal Revenue Service) says it can\u2019t comment on specific companies.
\"Inconsistency and ambiguity\" \u2014Tim Cook on the EU investigation.
Lienemeyer began assembling the Maxforce in late spring of 2013 with a mandate of scrutinizing tax policies across Europe in search of any favoritism. Direct subsidies or tax breaks to court a specific company are illegal in the EU to prevent governments aiding national champions.
His first hire -- the person who would oversee the Apple probe -- was Helena Malikova, a Slovak who had worked at Credit Suisse<\/a> Group AG in Zurich. He quickly added Kamila Kaukiel, a Polish financial analyst who had been at KPMG, and Saskia Hendriks, a former tax policy adviser to the Dutch government.
As the four initial members began their investigations, they got a head start from a US Senate probe of the tax strategies of American multinationals. The Senate\u2019s Permanent Subcommittee on Investigations said Apple shifted tens of billions of dollars in profit into stateless affiliates based in Ireland, where it secured a tax rate of less than 2 per cent.
At 9:30 a.m. on May 21, 2013, senators gathered in Room 106 of the Dirksen Office Building. Included in the evidence presented that day was a 2004 letter from Tom Connor, an official at Ireland\u2019s tax authority, to Ernst & Young, Apple\u2019s tax adviser.
Connor\u2019s question: A unit of the tech company hadn\u2019t filed a tax return; Was it still in business? E&Y responded two days later that the division was a non-resident holding company with no real sales. \"There is nothing to return from the corporation tax standpoint,\" E&Y wrote. The Senate exhibits didn\u2019t include Connor\u2019s response if there ever was one.
At the hearing, Arizona Republican John McCain castigated Apple as \"one of the biggest tax avoiders in America.\"
Democrat Carl Levin<\/a> of Michigan peered over the glasses perched on the tip of his nose and said Apple uses \"offshore tax strategies whose purpose is tax avoidance, pure and simple.\"
Crucially, though, Levin told the crowded room that under US law, there was little the panel could do to force Apple to pay more tax. Apple Chief Executive Officer Tim Cook passionately defended the company\u2019s actions, telling the senators \"We don\u2019t depend on tax gimmicks.\"
The Senate revelations raised eyebrows at the Maxforce\u2019s office in Madou Tower, a 1960s high-rise in the rundown Saint-Josse neighborhood of Brussels. Three weeks after the Senate hearing, Lienemeyer's team asked Ireland for details of Apple's tax situation.
The Irish tax authorities soon dispatched a representative carrying a briefcase filled with a bundle of bound pages.
The Irish could have simply sent the material via e-mail, but they were cautious about sharing taxpayer\u2019s information with the EU and have a ground rule to avoid leaks: never send such documents electronically.
While the Irish government remained bullish in its public statements, saying Apple hadn\u2019t received any favors, behind the scenes tensions were rising. Through the summer of 2013, the Finance Ministry assured government ministers that the EU investigation would amount to nothing, according to people familiar with the discussions.
But those assertions seemed less confident than earlier communications. There was a sense that Apple had worked out its Irish tax position in a vastly different era, and no one remembered many details of the negotiations decades earlier.
In 1980, the four-year-old company -- the Apple III desktop had just been released -- created several Irish affiliates, each with a different function such as manufacturing or sales, according to the Senate report. Under Irish laws dating to the 1950s designed to shore up the moribund post-war economy, as a so-called export company Apple paid no taxes on overseas sales of products made in Ireland.
To comply with European rules, Ireland finally ended its zero-tax policy in 1990. After that, Apple and Ireland agreed that the profit attributed to a key Ireland-based unit, the division discussed in Tom Connor\u2019s letter, be capped using a complex formula that in 1990 would have resulted in a taxable profit of $30 million to $40 million.
An Apple tax adviser \"confessed there was no scientific basis\" for those figures, but that the amounts would be \"of such magnitude that he hoped it would be seen as a bona-fide proposal,\" according to notes from a 1990 meeting with the Irish tax authority cited by the EU. The equation didn\u2019t change even as Apple began assembling the bulk of its products in Asia.
Ireland and Apple started to make changes a few months after the Maxforce began looking into their tax relationship. In October 2013, Finance Minister Noonan announced he would close the loophole that let stateless holding companies operate out of Ireland. And the EU says Apple changed the structure of its Irish units in 2015.
As the Maxforce stepped up its probe in June 2014, Irish Prime Minister Enda Kenny<\/a> was wooing potential investors in California. At a San Francisco event to promote Irish entrepreneurs, Governor Jerry Brown quipped that he had thought Apple \"was a California company,\" but according to tax returns, \"they\u2019re really an Irish company.\" News clips show Irish officials looking on stony-faced as the governor makes his jest.
Enforcement of EU rules on taxation is a matter of \"fairness\" \u2014EU competition chief, Margrethe Vestager
With Lienemeyer\u2019s team digging further into the issue, Apple\u2019s concern deepened. In January 2016, CEO Cook met with Margrethe Vestager, the EU competition chief -- and Lienemeyer's ultimate boss -- on the 10th-floor of the Berlaymont building, the institutional headquarters of the European Commission in Brussels.
Vestager, a daughter of two Lutheran pastors, has a reputation for being even-handed but tough, cutting unemployment benefits while advocating strict new rules for banks when she served as Denmark's finance minister.
While she has acknowledged that her team had little experience with tax rulings -- in a November interview with France's Society magazine, she said, \"We learned on the job\" -- Vestager says enforcement of EU rules on taxation is a matter of \"fairness.\"
In the meeting with Cook she quizzed him on the tax Apple paid in various jurisdictions worldwide. She told the Apple executives that \"someone has to tax you,\" according to a person present at the meeting.
In a Jan. 25 follow-up letter obtained by Bloomberg, Cook thanked Vestager for a \"candid and constructive exchange of views,\" and reasserted that Apple\u2019s earnings are \"subject to deferred taxation in the US until those profits are repatriated.\"
Subsequent correspondence became more heated. On March 14, Cook wrote to Vestager that he had \"concerns about the fairness of these proceedings.\" The Commission had failed to explain fully the basis on which Apple was being investigated, and the body's approach was characterized by \"inconsistency and ambiguity,\" Cook said.
Apple contended that the EU had backtracked on a 2014 decision recognizing that its two Irish subsidiaries were not technically resident in Ireland, and therefore only liable for taxes on profits derived from Irish sources.
Now, Cook said, it seemed the Commission was intent on \"imposing a massive, retroactive tax on Apple by attributing to the Irish branches all of Apple\u2019s global profits outside the Americas.\"
\"There is no inconsistency,\" an EU spokesman said in a Dec. 15 statement. Only a fraction of the profits of the subsidiaries were taxed in Ireland, the statement said. \"As a result, the tax rulings enabled Apple to pay substantially less tax than other companies, which is illegal under EU state aid rules.\"
Cook's entreaties did little to sway Vestager, and in August she phoned Noonan to tell him the results of the Maxforce investigation: The Commission was going to rule against Ireland. Late in the afternoon of Aug. 29, Irish officials began hinting to reporters that Apple\u2019s tax bill amounted to billions and \"could be anything.\"
At noon the following day, Vestager told a packed press conference in Brussels that the Commission had decided Apple owed Ireland 13 billion euros.
Though that would be equivalent to 26 percent of the 2015 national budget, Ireland didn't want the windfall, saying the ruling was flawed because the country hadn\u2019t given Apple any special treatment.
The decision sparked a political crisis as left-leaning members of Enda Kenny\u2019s fragile minority administration saw a potential bonanza for taxpayers that the world\u2019s richest company could well afford.
Even as Noonan toured television studios vowing to appeal the decision, independent lawmakers demanded that Ireland take the money.
Facing a potential revolt that could bring down the government, Kenny and Noonan eventually bowed to demands for a review of the country\u2019s corporate tax system. But they said they would fight the case, and on Sept. 7, Irish lawmakers overwhelmingly backed the motion for an appeal.
Officials from Lienemeyer\u2019s team and other EU offices say they have gathered tax information on about 300 companies, looking for what they deem to be favorable treatment by governments across Europe.
While they don't expect all of those to yield payoffs as hefty as that from their investigation of Ireland and Apple, they say a worrying number require the kind of maximum force that the Maxforce can apply.
\"We focus on outliers where you're looking at something that is off the radar screen,\" Lienemeyer's boss, 50-year-old Dutchman Gert-Jan Koopman, who is in charge of state-aid enforcement at the EU, said at a Brussels conference in November. \"If you're paying a fair amount of tax then there is absolutely nothing to worry about.\" <\/div><\/div>
Follow and connect with us on Twitter<\/a>, Facebook<\/a>, Linkedin<\/a>, Youtube<\/a><\/div>","HashCode":{"minfo":"-2079179035","minfoseo":"-2079179035"},"latestnewsflag":{"minfo":"1.0","minfoseo":"1-0"},"GEListMatchFound":{"minfo":"1","minfoseo":"1"},"GEPositiveNewsFlag":{"minfo":"1","minfoseo":"1"},"key":{"0":{"keyid":"6354427","value":"Apple","smid":"0","keynameseo":"Apple","keytype":"","keycount":"totalcount","weightage":"100"},"1":{"keyid":"298505","value":"Starbucks Corp","smid":"0","keynameseo":"Starbucks-Corp","keytype":"","keycount":"totalcount","weightage":"20"},"2":{"keyid":"3964578","value":"Maxforce","smid":"0","keynameseo":"Maxforce","keytype":"","keycount":"totalcount","weightage":"20"},"3":{"keyid":"3964577","value":"Max Lienemeyer","smid":"0","keynameseo":"Max-Lienemeyer","keytype":"","keycount":"totalcount","weightage":"20"},"4":{"keyid":"6358817","value":"Ireland","smid":"0","keynameseo":"Ireland","keytype":"","keycount":"totalcount","weightage":"20"},"5":{"keyid":"6355261","value":"Finance minister","smid":"0","keynameseo":"Finance-minister","keytype":"","keycount":"totalcount","weightage":"20"},"6":{"keyid":"614727","value":"European Union team","smid":"0","keynameseo":"European-Union-team","keytype":"","keycount":"totalcount","weightage":"20"},"7":{"keyid":"6355110","value":"European Union","smid":"0","keynameseo":"European-Union","keytype":"","keycount":"totalcount","weightage":"20"},"8":{"keyid":"848978","value":"Enda Kenny","smid":"0","keynameseo":"Enda-Kenny","keytype":"","keycount":"totalcount","weightage":"20"},"10":{"keyid":"48085","value":"Credit Suisse","smid":"0","keynameseo":"Credit-Suisse","keytype":"","keycount":"totalcount","weightage":"20"},"11":{"keyid":"250773","value":"Carl Levin","smid":"0","keynameseo":"Carl-Levin","keytype":"","keycount":"totalcount","weightage":"20"}},"authorsplit":[],"similarlytagged":[{"msid":"96873965","stname":"Tata nears iPhone plant takeover to grow Apple supply role","artsyn":"The airline-to-software conglomerate has been in talks with the factory\u2019s owner, Taiwan\u2019s Wistron Corp., for months, and is looking to complete the purchase by the end of March, according to two people familiar with the process.","seolocation":"telecomnews\/tata-nears-iphone-plant-takeover-to-grow-apple-supply-role","seolocationalt":"Tata nears iPhone plant takeover to grow Apple supply role","url_seo":"tata-nears-iphone-plant-takeover-to-grow-apple-supply-role"},{"msid":"96868377","stname":"Apple to replace key Broadcom chip with in-house design: Report","artsyn":"Apple plans to replace Broadcom's Wi-Fi and Bluetooth chip, according to the Bloomberg News report, which added that Apple is the U.S. chipmaker's largest customer.","seolocation":"telecomnews\/apple-to-replace-key-broadcom-chip-with-in-house-design-report","seolocationalt":"Apple to replace key Broadcom chip with in-house design: Report","url_seo":"apple-to-replace-key-broadcom-chip-with-in-house-design-report"},{"msid":"96868328","stname":"Apple's VP of services Stern to depart: Report","artsyn":"Stern, who joined the iPhone maker from Time Warner Cable in 2016, will leave at the end of the month, according to the report.","seolocation":"telecomnews\/apples-vp-of-services-stern-to-depart-report","seolocationalt":"Apple's VP of services Stern to depart: Report","url_seo":"apples-vp-of-services-stern-to-depart-report"},{"msid":"96855609","stname":"Broadcom addresses unfair practices, proposes measures worth $15.8 mn","artsyn":"The Fair Trade Commission (FTC) has been looking into allegations that Broadcom violated local laws by pressing Samsung Electronics Co. to ink long-term contracts for the supply of smart device parts.","seolocation":"telecomnews\/broadcom-addresses-unfair-practices-proposes-measures-worth-15-8-mn","seolocationalt":"Broadcom addresses unfair practices, proposes measures worth $15.8 mn","url_seo":"broadcom-addresses-unfair-practices-proposes-measures-worth-15-8-mn"},{"msid":"96855456","stname":"iPhone exports from India during April-December double to surpass $2.5 billion","artsyn":"Foxconn Technology Group and Wistron Corp. have each shipped more than $1 billion of Apple\u2019s marquee devices abroad in the first nine months of the fiscal year ending March 2023, people familiar with the matter said.","seolocation":"telecomnews\/iphone-exports-from-india-during-april-december-double-to-surpass-2-5-billion","seolocationalt":"iPhone exports from India during April-December double to surpass $2.5 billion","url_seo":"iphone-exports-from-india-during-april-december-double-to-surpass-2-5-billion"},{"msid":"96832870","stname":"Apple starts recruitments for India retail stores","artsyn":"The careers page in the Apple India website had four openings with references to Apple's retail business across various locations in India. These are potentially hundreds of jobs, as a typical Apple store has at least 100 employees, according to industry experts.","seolocation":"telecomnews\/apple-begins-hiring-retail-store-employees-in-india","seolocationalt":"Apple starts recruitments for India retail stores","url_seo":"apple-begins-hiring-retail-store-employees-in-india"},{"msid":"96804936","stname":"High-profile flops fill gallery at CES gadget fest","artsyn":"Iconic product failures were on display at this week's CES consumer electronics show included a skin-toning face mask reminiscent of a horror film; eyewear embedded with therapeutic magnets and a model of failed 80s sports car DeLorean.","seolocation":"telecomnews\/high-profile-flops-fill-gallery-at-ces-gadget-fest","seolocationalt":"High-profile flops fill gallery at CES gadget fest","url_seo":"high-profile-flops-fill-gallery-at-ces-gadget-fest"},{"msid":"96804891","stname":"The oven won't talk to the fridge: 'Smart' homes struggle","artsyn":"\u200b\u200bBig players from Amazon and Apple to Google and Samsung have built entire ecosystems for their devices, often around a voice assistant like Alexa or Siri.","seolocation":"telecomnews\/the-oven-wont-talk-to-the-fridge-smart-homes-struggle","seolocationalt":"The oven won't talk to the fridge: 'Smart' homes struggle","url_seo":"the-oven-wont-talk-to-the-fridge-smart-homes-struggle"},{"msid":"96804811","stname":"Discount scheme upsets the Apple cart for retailers in India","artsyn":"Retailers say Apple is forcing them to pay a part - Rs 800 per device - of the discount out of their own pocket. Additionally, the company is not compensating retailers for discounts on older inventory, which they had stocked in December at higher rates.","seolocation":"telecomnews\/discount-scheme-upsets-the-apple-cart-for-retailers-in-india","seolocationalt":"Discount scheme upsets the Apple cart for retailers in India","url_seo":"discount-scheme-upsets-the-apple-cart-for-retailers-in-india"},{"msid":"96783261","stname":"Tech companies keep slashing jobs in uncertain 2023 economy","artsyn":"In November, the most recent month for which data is available, the sector announced 52,771 cuts, for a total of 80,978 over the course of the year","seolocation":"telecomnews\/tech-companies-keep-slashing-jobs-in-uncertain-2023-economy","seolocationalt":"Tech companies keep slashing jobs in uncertain 2023 economy","url_seo":"tech-companies-keep-slashing-jobs-in-uncertain-2023-economy"},{"msid":"96778699","stname":"'Gut punch': Meta bruised in EU data fight","artsyn":"The Silicon Valley titan was handed a 390-million-euro ($413-million) fine on Wednesday as part of a years-long tussle with the European Union over data privacy.","seolocation":"telecomnews\/gut-punch-meta-bruised-in-eu-data-fight","seolocationalt":"'Gut punch': Meta bruised in EU data fight","url_seo":"gut-punch-meta-bruised-in-eu-data-fight"},{"msid":"96778609","stname":"View: Microsoft goes vocal for local for big tech","artsyn":"Microsoft chairman Satya Nadella's statement in an interview to ET that 'our licence to operate in any country fundamentally exists because we create local surplus' is an admission of interdependence by the maker of platforms on which enterprises across the world are parking chunks of business.","seolocation":"telecomnews\/microsoft-goes-vocal-for-local-for-big-tech","seolocationalt":"View: Microsoft goes vocal for local for big tech","url_seo":"microsoft-goes-vocal-for-local-for-big-tech"},{"msid":"96767864","stname":"Apple quietly launches new audiobook catalogue narrated by AI","artsyn":"The feature represents a major shift in audiobook publishing, which involves authors narrating their own books, a process that can take weeks and cost a publisher thousands of dollars, reports The Verge.","seolocation":"telecomnews\/apple-quietly-launches-new-audiobook-catalogue-narrated-by-ai","seolocationalt":"Apple quietly launches new audiobook catalogue narrated by AI","url_seo":"apple-quietly-launches-new-audiobook-catalogue-narrated-by-ai"},{"msid":"96762742","stname":"Apple supplier Foxconn December revenue drops 12% YoY","artsyn":"The company said revenue for December was better than its own expectations and that a \"gradual recovery\" at its Zhengzhou plant had contributed to \"double-digit growth\" in revenue for its smart consumer electronics business compared to November.","seolocation":"telecomnews\/apple-supplier-foxconn-december-revenue-drops-12-y\/y","seolocationalt":"Apple supplier Foxconn December revenue drops 12% YoY","url_seo":"apple-supplier-foxconn-december-revenue-drops-12-y\/y"},{"msid":"96755872","stname":"Apple to sign Luxshare for iPhone production in China: FT","artsyn":"Luxshare has been producing small numbers of the iPhone 14 Pro Max at its Kunshan plant, to make up for lost production at Foxconn's Zhengzhou factory last year, the report added.","seolocation":"telecomnews\/apple-to-sign-luxshare-for-iphone-production-in-china-ft","seolocationalt":"Apple to sign Luxshare for iPhone production in China: FT","url_seo":"apple-to-sign-luxshare-for-iphone-production-in-china-ft"},{"msid":"96755453","stname":"Apple's stock is losing its shine after ugly December","artsyn":"\"Apple has been seen as a flight to safety trade and when people kind of throw in the towel that's when they sell Apple,\" said Matt Maley of Miller Tabak + Co. \"When we reach a bottom, Apple tends to get washed out and cheap and it's still, if anything, slightly expensive.\"","seolocation":"telecomnews\/apples-stock-is-losing-its-shine-after-ugly-december","seolocationalt":"Apple's stock is losing its shine after ugly December","url_seo":"apples-stock-is-losing-its-shine-after-ugly-december"},{"msid":"96750985","stname":"Luxshare says client cooperation normal after Apple production cut report","artsyn":"The electronics manufacturer said it wanted to clarify a recent report from a Taiwanese media outlet which said that Luxshare had suffered the biggest impact from the Apple request.","seolocation":"telecomnews\/luxshare-says-client-cooperation-normal-after-apple-production-cut-report","seolocationalt":"Luxshare says client cooperation normal after Apple production cut report","url_seo":"luxshare-says-client-cooperation-normal-after-apple-production-cut-report"},{"msid":"96750972","stname":"French privacy watchdog fines Apple over personalised ads","artsyn":"\"The advertising targeting settings available from the \"Settings\" icon of the iPhone were pre-checked by default\", the CNIL said in a statement, even though that was not strictly necessary for the device's functioning.","seolocation":"telecomnews\/french-privacy-watchdog-fines-apple-over-personalised-ads","seolocationalt":"French privacy watchdog fines Apple over personalised ads","url_seo":"french-privacy-watchdog-fines-apple-over-personalised-ads"},{"msid":"96724069","stname":"Foxconn to use Nvidia chips to build self-driving vehicle platforms","artsyn":"Taiwanese contract manufacturer Foxconn said it will manufacture electronic control units (ECUs) for cars based on Nvidia's DRIVE Orin chip made specifically for computing in connected and autonomous vehicles.","seolocation":"telecomnews\/foxconn-to-use-nvidia-chips-to-build-self-driving-vehicle-platforms","seolocationalt":"Foxconn to use Nvidia chips to build self-driving vehicle platforms","url_seo":"foxconn-to-use-nvidia-chips-to-build-self-driving-vehicle-platforms"},{"msid":"96723874","stname":"Apple's stock market value falls below $2 trillion","artsyn":"Apple's shares declined 3.7% to $125.07 after Exane BNP Paribas analyst Jerome Ramel downgraded the company to \"neutral\" from \"outperform,\" slashing his price target to $140 from $180, according to Refinitiv Eikon.","seolocation":"telecomnews\/apples-stock-market-value-falls-below-2-trillion","seolocationalt":"Apple's stock market value falls below $2 trillion","url_seo":"apples-stock-market-value-falls-below-2-trillion"}],"primeid":0,"storytags":{"categoryTag":{"sectionid":"49830939","sectionname":"TelecomNews","seolocation":"telecomnews","seolocationalt":"telecomnews"},"otherTags":[{"keyid":"6354427","value":"Apple","smid":"0","keynameseo":"Apple","keytype":"","keycount":"totalcount","weightage":"100"},{"keyid":"298505","value":"Starbucks Corp","smid":"0","keynameseo":"Starbucks-Corp","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"3964578","value":"Maxforce","smid":"0","keynameseo":"Maxforce","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"3964577","value":"Max Lienemeyer","smid":"0","keynameseo":"Max-Lienemeyer","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"6358817","value":"Ireland","smid":"0","keynameseo":"Ireland","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"6355261","value":"Finance minister","smid":"0","keynameseo":"Finance-minister","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"614727","value":"European Union team","smid":"0","keynameseo":"European-Union-team","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"6355110","value":"European Union","smid":"0","keynameseo":"European-Union","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"848978","value":"Enda Kenny","smid":"0","keynameseo":"Enda-Kenny","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"6355190","value":"Devices","smid":"0","keynameseo":"Devices","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"48085","value":"Credit Suisse","smid":"0","keynameseo":"Credit-Suisse","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"250773","value":"Carl Levin","smid":"0","keynameseo":"Carl-Levin","keytype":"","keycount":"totalcount","weightage":"20"}],"filterTags":[]},"formattedTags":{"companyTags":[],"otherTags":[{"name":"European Union team"},{"name":"Finance minister"},{"name":"Starbucks Corp"},{"name":"Max Lienemeyer"},{"name":"European Union"},{"name":"Credit Suisse"},{"name":"Enda Kenny"},{"name":"Carl Levin"},{"name":"Maxforce"},{"name":"Ireland"},{"name":"Devices"},{"name":"Apple"}],"newsCategoryTags":[{"name":"TelecomNews","seolocation":"telecomnews"}],"breadcrumbTags":["Apple","Starbucks Corp","Maxforce","Max Lienemeyer","Ireland","Finance minister","European Union team","European Union","Enda Kenny","Devices","Credit Suisse","Carl Levin"],"filterTags":[]},"breadcrumbTags":["Apple","Starbucks Corp","Maxforce","Max Lienemeyer","Ireland","Finance minister","European Union team","European Union","Enda Kenny","Devices","Credit Suisse","Carl Levin"],"Alttitle":{"minfo":""},"Altdescription":{"minfo":""},"amp_url":"\/\/www.iser-br.com\/amp\/news\/the-inside-story-of-apples-14-billion-tax-bill\/56020909","associated":{"articles":{"96873965":{"msid":"96873965","stname":"Tata nears iPhone plant takeover to grow Apple supply role","artsyn":"The airline-to-software conglomerate has been in talks with the factory\u2019s owner, Taiwan\u2019s Wistron Corp., for months, and is looking to complete the purchase by the end of March, according to two people familiar with the process.","seolocation":"telecomnews\/tata-nears-iphone-plant-takeover-to-grow-apple-supply-role","seolocationalt":"Tata nears iPhone plant takeover to grow Apple supply role","url_seo":"tata-nears-iphone-plant-takeover-to-grow-apple-supply-role"},"96868377":{"msid":"96868377","stname":"Apple to replace key Broadcom chip with in-house design: Report","artsyn":"Apple plans to replace Broadcom's Wi-Fi and Bluetooth chip, according to the Bloomberg News report, which added that Apple is the U.S. chipmaker's largest customer.","seolocation":"telecomnews\/apple-to-replace-key-broadcom-chip-with-in-house-design-report","seolocationalt":"Apple to replace key Broadcom chip with in-house design: Report","url_seo":"apple-to-replace-key-broadcom-chip-with-in-house-design-report"},"96868328":{"msid":"96868328","stname":"Apple's VP of services Stern to depart: Report","artsyn":"Stern, who joined the iPhone maker from Time Warner Cable in 2016, will leave at the end of the month, according to the report.","seolocation":"telecomnews\/apples-vp-of-services-stern-to-depart-report","seolocationalt":"Apple's VP of services Stern to depart: Report","url_seo":"apples-vp-of-services-stern-to-depart-report"},"96855609":{"msid":"96855609","stname":"Broadcom addresses unfair practices, proposes measures worth $15.8 mn","artsyn":"The Fair Trade Commission (FTC) has been looking into allegations that Broadcom violated local laws by pressing Samsung Electronics Co. to ink long-term contracts for the supply of smart device parts.","seolocation":"telecomnews\/broadcom-addresses-unfair-practices-proposes-measures-worth-15-8-mn","seolocationalt":"Broadcom addresses unfair practices, proposes measures worth $15.8 mn","url_seo":"broadcom-addresses-unfair-practices-proposes-measures-worth-15-8-mn"},"96855456":{"msid":"96855456","stname":"iPhone exports from India during April-December double to surpass $2.5 billion","artsyn":"Foxconn Technology Group and Wistron Corp. have each shipped more than $1 billion of Apple\u2019s marquee devices abroad in the first nine months of the fiscal year ending March 2023, people familiar with the matter said.","seolocation":"telecomnews\/iphone-exports-from-india-during-april-december-double-to-surpass-2-5-billion","seolocationalt":"iPhone exports from India during April-December double to surpass $2.5 billion","url_seo":"iphone-exports-from-india-during-april-december-double-to-surpass-2-5-billion"},"96832870":{"msid":"96832870","stname":"Apple starts recruitments for India retail stores","artsyn":"The careers page in the Apple India website had four openings with references to Apple's retail business across various locations in India. These are potentially hundreds of jobs, as a typical Apple store has at least 100 employees, according to industry experts.","seolocation":"telecomnews\/apple-begins-hiring-retail-store-employees-in-india","seolocationalt":"Apple starts recruitments for India retail stores","url_seo":"apple-begins-hiring-retail-store-employees-in-india"},"96804936":{"msid":"96804936","stname":"High-profile flops fill gallery at CES gadget fest","artsyn":"Iconic product failures were on display at this week's CES consumer electronics show included a skin-toning face mask reminiscent of a horror film; eyewear embedded with therapeutic magnets and a model of failed 80s sports car DeLorean.","seolocation":"telecomnews\/high-profile-flops-fill-gallery-at-ces-gadget-fest","seolocationalt":"High-profile flops fill gallery at CES gadget fest","url_seo":"high-profile-flops-fill-gallery-at-ces-gadget-fest"},"96804891":{"msid":"96804891","stname":"The oven won't talk to the fridge: 'Smart' homes struggle","artsyn":"\u200b\u200bBig players from Amazon and Apple to Google and Samsung have built entire ecosystems for their devices, often around a voice assistant like Alexa or Siri.","seolocation":"telecomnews\/the-oven-wont-talk-to-the-fridge-smart-homes-struggle","seolocationalt":"The oven won't talk to the fridge: 'Smart' homes struggle","url_seo":"the-oven-wont-talk-to-the-fridge-smart-homes-struggle"},"96804811":{"msid":"96804811","stname":"Discount scheme upsets the Apple cart for retailers in India","artsyn":"Retailers say Apple is forcing them to pay a part - Rs 800 per device - of the discount out of their own pocket. Additionally, the company is not compensating retailers for discounts on older inventory, which they had stocked in December at higher rates.","seolocation":"telecomnews\/discount-scheme-upsets-the-apple-cart-for-retailers-in-india","seolocationalt":"Discount scheme upsets the Apple cart for retailers in India","url_seo":"discount-scheme-upsets-the-apple-cart-for-retailers-in-india"},"96783261":{"msid":"96783261","stname":"Tech companies keep slashing jobs in uncertain 2023 economy","artsyn":"In November, the most recent month for which data is available, the sector announced 52,771 cuts, for a total of 80,978 over the course of the year","seolocation":"telecomnews\/tech-companies-keep-slashing-jobs-in-uncertain-2023-economy","seolocationalt":"Tech companies keep slashing jobs in uncertain 2023 economy","url_seo":"tech-companies-keep-slashing-jobs-in-uncertain-2023-economy"},"96778699":{"msid":"96778699","stname":"'Gut punch': Meta bruised in EU data fight","artsyn":"The Silicon Valley titan was handed a 390-million-euro ($413-million) fine on Wednesday as part of a years-long tussle with the European Union over data privacy.","seolocation":"telecomnews\/gut-punch-meta-bruised-in-eu-data-fight","seolocationalt":"'Gut punch': Meta bruised in EU data fight","url_seo":"gut-punch-meta-bruised-in-eu-data-fight"},"96778609":{"msid":"96778609","stname":"View: Microsoft goes vocal for local for big tech","artsyn":"Microsoft chairman Satya Nadella's statement in an interview to ET that 'our licence to operate in any country fundamentally exists because we create local surplus' is an admission of interdependence by the maker of platforms on which enterprises across the world are parking chunks of business.","seolocation":"telecomnews\/microsoft-goes-vocal-for-local-for-big-tech","seolocationalt":"View: Microsoft goes vocal for local for big tech","url_seo":"microsoft-goes-vocal-for-local-for-big-tech"},"96767864":{"msid":"96767864","stname":"Apple quietly launches new audiobook catalogue narrated by AI","artsyn":"The feature represents a major shift in audiobook publishing, which involves authors narrating their own books, a process that can take weeks and cost a publisher thousands of dollars, reports The Verge.","seolocation":"telecomnews\/apple-quietly-launches-new-audiobook-catalogue-narrated-by-ai","seolocationalt":"Apple quietly launches new audiobook catalogue narrated by AI","url_seo":"apple-quietly-launches-new-audiobook-catalogue-narrated-by-ai"},"96762742":{"msid":"96762742","stname":"Apple supplier Foxconn December revenue drops 12% YoY","artsyn":"The company said revenue for December was better than its own expectations and that a \"gradual recovery\" at its Zhengzhou plant had contributed to \"double-digit growth\" in revenue for its smart consumer electronics business compared to November.","seolocation":"telecomnews\/apple-supplier-foxconn-december-revenue-drops-12-y\/y","seolocationalt":"Apple supplier Foxconn December revenue drops 12% YoY","url_seo":"apple-supplier-foxconn-december-revenue-drops-12-y\/y"},"96755872":{"msid":"96755872","stname":"Apple to sign Luxshare for iPhone production in China: FT","artsyn":"Luxshare has been producing small numbers of the iPhone 14 Pro Max at its Kunshan plant, to make up for lost production at Foxconn's Zhengzhou factory last year, the report added.","seolocation":"telecomnews\/apple-to-sign-luxshare-for-iphone-production-in-china-ft","seolocationalt":"Apple to sign Luxshare for iPhone production in China: FT","url_seo":"apple-to-sign-luxshare-for-iphone-production-in-china-ft"},"96755453":{"msid":"96755453","stname":"Apple's stock is losing its shine after ugly December","artsyn":"\"Apple has been seen as a flight to safety trade and when people kind of throw in the towel that's when they sell Apple,\" said Matt Maley of Miller Tabak + Co. \"When we reach a bottom, Apple tends to get washed out and cheap and it's still, if anything, slightly expensive.\"","seolocation":"telecomnews\/apples-stock-is-losing-its-shine-after-ugly-december","seolocationalt":"Apple's stock is losing its shine after ugly December","url_seo":"apples-stock-is-losing-its-shine-after-ugly-december"},"96750985":{"msid":"96750985","stname":"Luxshare says client cooperation normal after Apple production cut report","artsyn":"The electronics manufacturer said it wanted to clarify a recent report from a Taiwanese media outlet which said that Luxshare had suffered the biggest impact from the Apple request.","seolocation":"telecomnews\/luxshare-says-client-cooperation-normal-after-apple-production-cut-report","seolocationalt":"Luxshare says client cooperation normal after Apple production cut report","url_seo":"luxshare-says-client-cooperation-normal-after-apple-production-cut-report"},"96750972":{"msid":"96750972","stname":"French privacy watchdog fines Apple over personalised ads","artsyn":"\"The advertising targeting settings available from the \"Settings\" icon of the iPhone were pre-checked by default\", the CNIL said in a statement, even though that was not strictly necessary for the device's functioning.","seolocation":"telecomnews\/french-privacy-watchdog-fines-apple-over-personalised-ads","seolocationalt":"French privacy watchdog fines Apple over personalised ads","url_seo":"french-privacy-watchdog-fines-apple-over-personalised-ads"},"96724069":{"msid":"96724069","stname":"Foxconn to use Nvidia chips to build self-driving vehicle platforms","artsyn":"Taiwanese contract manufacturer Foxconn said it will manufacture electronic control units (ECUs) for cars based on Nvidia's DRIVE Orin chip made specifically for computing in connected and autonomous vehicles.","seolocation":"telecomnews\/foxconn-to-use-nvidia-chips-to-build-self-driving-vehicle-platforms","seolocationalt":"Foxconn to use Nvidia chips to build self-driving vehicle platforms","url_seo":"foxconn-to-use-nvidia-chips-to-build-self-driving-vehicle-platforms"},"96723874":{"msid":"96723874","stname":"Apple's stock market value falls below $2 trillion","artsyn":"Apple's shares declined 3.7% to $125.07 after Exane BNP Paribas analyst Jerome Ramel downgraded the company to \"neutral\" from \"outperform,\" slashing his price target to $140 from $180, according to Refinitiv Eikon.","seolocation":"telecomnews\/apples-stock-market-value-falls-below-2-trillion","seolocationalt":"Apple's stock market value falls below $2 trillion","url_seo":"apples-stock-market-value-falls-below-2-trillion"}}}}" data-news-images="[{"msid":"56020931","msname":"Apple","msnameseo":"apple","mediatype":"1","artdate":"2016-12-16 17:43:00.0","caption":" The increased level of interest in India is happening in the backdrop of concern among Apple's investors that the company may have hit a plateau."}]" data-newsletter-by="0" data-newsletter-date="a" data-hasbottomcarousel="" data-alldetailsopen="0" data-multipleanalyticshit="" data-deeplink="https://ettelecom.app.link?$deeplink_path=" data-socialshareformat="default">
