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Ah, I see. A USA mate said he ended up paying extra tax, but perhaps he didn't know the rules well enough.
There are no overriding EU corporation tax rules: ROI set their own, much lower corporation tax, which is OK, but they let only Apple get away with paying much less than that (Starbucks did the same in NL, they also got in trouble)
What tax rule would stop Apple bring cash in?
JWestland-
There are no overriding EU corporation tax rules: ROI set their own, much lower corporation tax, which is OK, but they let only Apple get away with paying much less than that (Starbucks did the same in NL, they also got in trouble)
I meant the rules that stop them being given a special deal.
Apple getting their money into ROI doesn't help them. If it ever needs to be anywhere other than offshore then it needs to be in the US. Going through another country en route to the US is only going to cost them more. They're going to wait until they can go direct or just keep it offshore and borrowing against it there.
Greenbank
US citizens have to pay US tax on their earnings wherever they are in the world but they get 1-for-1 credit for any local tax paid. So if your local tax bill is less than the US tax bill you owe the rest to the US. If your local tax bill is the same or more than the US tax bill then you don't pay anything to the US. Even the US doesn't do double taxation.
(I should really look into the tax I paid when I worked in the US, I'm probably due some of it back but it was a long time ago...)
Apple will never bring it onshore in the ROI as long as the overriding EU tax rules make it not worth it. If anything, Apple (and many many other corps) are waiting for another reduced rate US tax amnesty so they can get it into the US although they don't really need to; they can do all of their R&D and M&A on loaned money with the offshore stuff as guarantor and available to bring chunks of it in tax-free to pay the interest on the loans.