tag:blogger.com,1999:blog-2826531655042170344.post1071397956051944065..comments2024-03-26T11:29:52.986+00:00Comments on Economic Incentives: Why tax campaigners should be aghast at the Apple rulingSeamushttp://www.blogger.com/profile/15679299530222667673noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-2826531655042170344.post-36421410927974248532016-09-03T14:56:37.672+01:002016-09-03T14:56:37.672+01:00I think this rather misses the point that the Comm...I think this rather misses the point that the Commission has found that the head office of ASI does not actually carry out the management and control functions attributed to it, and on which the attribution of profits to the Irish company is based. It did not make decisions about Apple's global sales, but only about where to route the money.<br /><br />In your French example, if the decisions about the company's operations are actually being made in France, that is where tax is applied. The problem is that in ASI's case, according to the Commission, they're not being made where Apple claims they're being made.<br /><br />If they're not being made at ASI's head office, then either they're being made at Apple Inc - in which case that's where profits should be attributed, not in ASI - or they're being made in ASI's Irish branch.<br /><br />The Commission seems essentially to be forcing Apple to choose between those options. Neither of them, though, open the door to the wholesale tax haven setups you suggest.ibishttp://www.politics.ienoreply@blogger.com