The Commission alleges that ‘Apple only paid an effective corporate tax rate that declined from 1 per cent in 2003 to 0.005 per cent in 2014 on the profits of Apple Sales International.’1 What matters is what Apple ultimately pays in tax on a global basis, including US repatriation taxes, rather than what its international subsidiaries pay in one or another jurisdiction. However, the Commission appears to be less interested in the rules governing taxation of global multinational companies, and rather more interested in gaining some political capital.

Authors: Clement Mifsud-Bonnici and Liza Lovdahl Gormsen

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