|Between the three Irish Apple Companies - ASI, AOE and AOI -
and Apple (and
Braeburn) in the US is the "Ocean". By
transfer pricing, switching
IP/Licensing the 'Cost
Agreement' allows them to transfer income
places (almost definitely including some from the US).
tax purposes the last Irish holding companies is not
resident in any
jurisdiction - "in the Ocean" -
in tax 'planning'/avoidance terms
with ZERO tax
rates (while, of course, the 'cash' is actually
in various US
other securities and bonds under Braeburn's
as Ireland considers it to be under
Foreign - Apple US -
control. However, this does not
quite seem to tally with the
requirements of the US
authorities. That is why the question
companies" was the telling one. Each
witness had to
was controlled from the US.
See "Testimony of
Stephen E. Shay" (pdf)
from US Senate Subcommittee.
May 21, 2013
This is more than just 'gaming' the system!
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