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by csomar 3208 days ago
Can you explain what are these tricks? Asking for a friend. A link is fine too.
3 comments

Basic trick:

- Apple France is actually just a distributor for Apple Ireland

- Apple Ireland sells Apple France an iPhone at MSRP

- Apple France makes basically no profit because it sells "at cost"

- Apple Ireland books a profit for an iPhone sold in France

That sounds way too easy... Is there any extra sleight of hand required? I'm surprised they can get a way with such blatant maneuvers.
As I understand it, there is also some monkey business related to patents. Something like this: Apple sells its patents to Apple Ireland for a dollar. Then they pay "royalties" to Apple Ireland everytime they sell an iPhone. I can't confirm where I read this.
My understanding is this structure is also possible in a "legitimate" setting

For example if Apple France is really just a distributor, and they buy their products at low margins, then it is what it is

I think a lot of tax agencies simply don't have the muscle to push forward on this

The most powerful politician in the EU - Jean-Claude Juncker - is personally responsible (not by himself, of course) for setting up these sorts of structures, and making sure they stay in place [1].

A quote from [1]:

"The president of the European commission, Jean-Claude Juncker, spent years in his previous role as Luxembourg’s prime minister secretly blocking EU efforts to tackle tax avoidance by multinational corporations, leaked documents reveal."

So:

> I think a lot of tax agencies simply don't have the muscle to push forward on this

No. They do. They're just prevented from doing so by the "socialists" (hah !) Europe "elected" (just pointing out that the leadership of the EU commission, the only organisation with real law-giving power in the EU aren't directly elected at all).

[1] https://www.theguardian.com/business/2017/jan/01/jean-claude...

1.Have multiple subsidiaries of the same company in different countries.

2.Give intellectual property rights to one company in one country with low taxation like Ireland or a state like Maryland.

3. Make all the subsidiaries pay arbitrary patent-copyright-trademark rights to the company in Ireland-Maryland-Singapur so all the profits become zero in the different countries while transferring all those profits away.

It's been widely reported on by major news outlets over the years. Dutch Sandwitch (now defunct?) was one of them.
The double Irish with a Dutch sandwich is still available and actively being used until 2020.

https://en.wikipedia.org/wiki/Double_Irish_arrangement