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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Replying to @MForstater
No, branch profit allocation to Irish branch of "stateless" companies.
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Replying to @AislingTax
...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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Replying to @MForstater
no, Ireland was an outlier. Eg UK changed its rules in 1987. Q is whether the untaxed profits are sales or IP?
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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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that’s what I’m wondering? Is it saying that wherever had the sales hub shld hav had 60% of tax base?!
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Replying to @MForstater @iaincampbell07 and
(60% of the global tax base, 100% of the profit on those sales…)
7:05 AM - 31 Aug 2016
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