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Apple: The King of international taxation

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Apple Optimisation fiscale

Apparently offshore companies have no longer secrets for Apple. This is essentially what has been unveiled by a report from a U.S. Senate committee. Indeed, Apple, despite the fact of being the first customer of the IRS in having paid more than $ 6 billion tax, it remains that its tax optimization through offshore companies is one of the better ones that can exist.

As a priority, Apple was able to negotiate with the Irish Revenue, a much lower tax rate than normally found in this country where the U.S. group manages most of its international business tax rate. Its tax rate is only 2 % instead of the normal 12%; a beautiful gift tax of 10%. It is obvious that this gift has undoubtedly been negotiated by the group because otherwise there would be discrimination with tax. But this “legal” provision is nothing in comparison with the main offshore group company.

Apple holding: International Operation

Because its hidden tax iceberg is really the company Apple Operations International. Because this company oversees all operations in Asia, Europe, the Middle East, India and Africa. In short, all global activities aside those made in America (North and South) and Australia. A company that has completed over $ 30 billion of income between 2009 and 2011. Yet this company is almost a ghost because it has not paid a dime of taxes, while it allows the group to achieve about one third of its profits.

The mounting of this company in question is actually quite simple. This structure has no offices. There is only a PO Box located in Ireland. And as no country around the world sees it as a tax resident, it is not considered taxable. The United States does not tax it either because it is domiciled in Ireland. And as the board that manages it met in America, Ireland, under its law, cannot see it as an Irish tax resident. Apple has simply taken advantage of lawless areas between the two countries.

Apple: Its official communication on taxation

Apple Optimisation fiscale

Apple Optimisation fiscale

Apple also recognizes that this company is tax resident anywhere. And this is not in fact the only company of Apple group in this case, since the group also creates another company named Apple Operations Europe that benefits the same system. Although the results of this structure are less important than the previous one, it remains that no tax is paid on it. Finally, Apple’s latest company which is the responsible of the worldwide sale of Iphone or Ipad is also domiciled in Ireland and also benefits from the largesse of the offshore. Because even if the group pays taxes on this structure, the amount is insignificant. Just 0.5% of the turnover of the structure.

All this, not to mention, of course, companies in France where three subsidiaries were based. The first who does not file its accounts, a second which is losing (and therefore not paying tax) and a final which states only a portion of the turnover achieved in France. Because even if the sales are realized in France, they are made by intermediaries (wholesalers, mobile operators, etc.) which themselves are charged by Irish society. In addition, it would also appear that each of Irish companies have as a shareholder a company called Baldwin Holdings Unlimited registered in the British Virgin Islands, one of the best known tax haven. Finally, within the United States, Apple Group manages its cash through a subsidiary located in Nevada, a state in which taxes are zero. A true spider canvas offshore!

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