Q for taxtweeps: the big $s in Apple case are down to the mismatch on treatment of tax residency of ASI, right? EIRE says US, US says not..
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No, branch profit allocation to Irish branch of "stateless" companies.
...the Q i'm wondering about is would the 'statelessness' issue be the same if European hub was in a different country?
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no, Ireland was an outlier. Eg UK changed its rules in 1987. Q is whether the untaxed profits are sales or IP?
@AislingTax -
EU seems to be taking the sales approach and alloted to Ireland. Is it me, or does this not stand up?.
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I think statelessness is both a red herring from irish PoV, and makes it more difficult to defend without creating US tax risk
Thanks. Twitter will use this to make your timeline better. UndoUndo
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