Apple & other big companies in Ireland may have to pay Irish back-tax
EUROPEAN COMMISSION COULD FORCE STATE TO RECOVER PAST TAXES, TECH GIANT WARNS
In a letter to the Irish Government in June, commissioner Joaquín Almunia said in each year Apple had paid between €1 million and €10 million in Irish corporation tax.
Apple has warned shareholders it may have to pay a material amount of back-tax to Ireland if the European Commission’s inquiry into its arrangements in the Republic finds they constituted state aid.
The company has further warned shareholders that a ruling against Ireland could mean the company would have to pay more tax on its profits in future years.
It is normal for public companies in the US to warn shareholders of so-called “risk factors” that could have a material effect on their results.
No figures for the possible size of any such repercussions are given.
However the latestannual return for Apple, filed recently with the Securities and Exchange Commission in Washington, DC, makes clear the enormous role played by Ireland in the multinational’s global structures.
SUBSIDIARIES
The company has accumulated almost $70 billion in profits from non-US operations that have not been subjected to US corporation tax and which have largely been booked by Apple subsidiaries “organised in Ireland”.
These are understood to include the two so-called “stateless” Apple subsidiaries that have registered addresses in Cork but which up until recently have not been tax resident anywhere.
It is Ireland’s tax arrangements with these companies that are the focus of the state aid inquiry being conducted by the commission. Ireland is contesting its charge that agreements arrived at by the companies and the Revenue Commissioners, in 1991 and 2007, constituted state aid. A request yesterday for a comment from Apple met with no response.
In its annual report Apple said its effective tax rate and other aspects of its tax regime could be subject to significant change because of developments concerning tax laws and their interpretation. In the latter regard it mentioned only two jurisdictions, the US and Ireland.
“For example, in June 2014 the European Commissionopened a formal investigation to examine whether decisions by the tax authorities in Ireland with regard to the corporate income tax to be paid by two of the company’s Irish subsidiaries comply with European Union rules on state aid,” the filing said.
“If the European Commission were to take a final decision against Ireland, it could require changes to existing tax rulings that, in turn, could increase the company’s taxes in the future.”
“The European Commission could also require Ireland to recover from the company past taxes reflective of the disallowed state aid.”
IRISH CORPORATION TAX
The subsidiaries are Apple Sales International (ASI) and Apple Operations Europe. Despite having sales that totalled more than $150 billion in the four years to 2012 they have paid less than €10 million a year in Irish corporation tax.
In a letter to the Irish Government in June, commissioner Joaquín Almunia quoted figures from a US senate inquiry into Apple’s tax affairs which found ASI’s pretax profits in the three years from 2009 were, respectively $4 billion, $12.1 billion and $22 billion.
However, the Irish authorities had told the commission the company’s taxable profits in Ireland had been between €30 million to €40 million for 2009 and 2010; between €50 million and €60 million in 2011; and between €40 million and €50 million in 2012.
In each year the company had paid between €1 million and €10 million in Irish corporation tax, the letter said.
Ireland’s arrangement with the companies involved their taxable profits attributable to Ireland being a percentage of their operational expenses. Apart from these profits, the companies were not tax resident anywhere.
Water pressure rises as Government gives €100 off every bill
GOVERNMENT TRIES TO QUELL ANGER AT WATER CHARGES WITH €100 OFF EVERY BILL
Protesters pictured at a meeting between Cork City and County Councils with Irish Water at the Silver Springs Moran Hotel, Cork. Photo: Daragh Mc Sweeney/Provision
The Government is planning to extend the water charges tax relief to ensure everyone is guaranteed €100 off their bill, the Irish Independent has learned.
The move – seen as the Government yielding to mounting pressure from water protests across the country – ensures for the first time that every single household gets €100 off their bill.
Separately, a social welfare payment of €100 will now only be made to welfare recipients once the bill has been paid.
And a cap on water charges is also under consideration, but householders with a meter would still be able to pay the metered rate if it was lower.
The Irish Independent understands that water meter installers were “imprisoned” by protesters for 12 hours in a Dublin housing estate on Wednesday night. Fifteen contracted workers were trapped in their vans with no access to food or water during the stand-off, which ended at 2am.
Gardai maintained a watching brief until the 70-strong crowd dispersed peacefully.
Following the Budget, taxpayers will be able to claim water charges tax relief worth up to €100 a year at the lower income tax rate of 20pc.
The bill for a family of two adults and two children is estimated at €278, meaning tax relief of €55.60.
The relief is capped at €100, which would require a bill of €500.
But the Government is now weighing up ensuring everyone gets the full €100 tax refund, regardless of the size of the bill.
“Give everyone the same subsidy. You know what you pay. You know what you’re getting back,” a senior Coalition source said.
The tax relief is already available to everyone, regardless of income. But it has to be claimed back from the Revenue Commissioners a year later and taxpayers have to be able to prove they paid their bills.
The Government is examining ways to speed up this process of refunding from Revenue.
On the social welfare side, 600,000 social welfare recipients will get a €100 payment to offset water charges. But the social welfare recipients do not currently have to prove they are paying their bills to get the benefit.
The Coalition is exploring ways to link the payment directly to payment.
“Everybody will get the same. Any new subsidy mechanism has to be linked to people signing up and paying,” a source said.
Ministers are continuing to discuss ways to quell growing public opposition to the water charges.
No firm proposals are expected for at least two weeks.
“We have one last shot. Whatever we do has to be definitive, radical enough and we can’t go back to it again,” a Coalition source said.
Taoiseach Enda Kenny, Tanaiste Joan Burton and four key Government ministers met for three-and-a-half hours yesterday to review efforts to defuse mounting public opposition to Irish Water and the planned water charges.
The meeting came as anti-water charge campaigners said they will have as many as 80 demonstrations in centres right across the country tomorrow.
Ministers also discussed the structure of the new board of Ervia – the new combined structure of Irish Water and Bord Gais.
Government sources indicated there will be widespread changes with experts in legal, financial, water and market areas. “To reinstate Irish Water and how it is perceived in the public mind, that board will have to be of appropriate calibre,” a source said.
BONUSES
Mr Kenny and Ms Burton discussed the water charges plan with Finance Minister Michael Noonan and Public Spending Minister Brendan Howlin. The meeting was also attended by Environment Minister Alan Kelly and Communications Minister Alex White who are closely concerned with the topic.
Irish Water paying staff bonuses will not help the company’s need to win public confidence, Public Expenditure Minister Brendan Howlin has said.
But Mr Howlin also said the Government cannot control staff pay in semi-State bodies like Irish Water. “I think there is for a new company like Irish Water certainly a view that bonuses should not be paid. Ultimately that will be a matter for the board. But I think they need to win the confidence of people,” he said.
Officials said discussions would continue on finding ways of reassuring people that Irish Water will work effectively and water bills will be affordable. One official pointed out that there are already assurances that people with regular work will get tax concessions on charges while those dependent on welfare will also get additional help.
Other changes now under consideration focus on keeping a fixed flat rate charge for a given period until metering is well advanced and citizens could be reassured that the water bills will not be excessive. Other measures, like extra allowances for homes with a number of adults and similar measures for homes with more teenagers, are also being looked at.
Pay rates for new consultants rejected by Irish Medical Organisation
Overwhelming vote by doctors against proposals should be ‘a wake-up call’ for Minister Leo Varadkar , The IMO says.
Last week Minister for Health Leo Varadkar said he would support newly-appointed hospital consultants receiving pay parity with colleagues employed before October 2012.
The Government will have to consider its options for filling hundreds of vacant consultant posts in hospitals after doctors rejected revised pay rates, the Minister for HealthLeo Varadkar has said.
Doctors who are members of the Irish Medical Orgaisation (IMO) have voted overwhelmingly to reject revised pay rates for newly-appointed hospital consultants which ranged from €125,000 to €175,000.
The proposals, which were brokered at the Labour Relations Commission in September, also allowed for consultants with experience abroad to enter the Irish public hospital system at a salary level of up to €155,000 rather than at the starting point on the scale.
Mr Varadkar tonight described the ballot result as “very disappointing”.
“The proposed salary scale ranging from €127,000 to €175,000 is very good by any reckoning. The real losers today are patients,” he said. “The Government will now have to consider its options in filling the consultant vacancies.”
Up to 300 consultant posts in public hospitals are currrently vacant – a situation which medical organisations blame directly on a controversial Government decision in October 2012 to cut by 30 per cent the salary of specialist doctors appointed after that date.
IMO director of industrial relations Steve Tweed said that the result of the ballot had not come as a surprise.
“”We repeatedly warned the HSE that the proposals put forward by management through the Labour Relations Commission were insufficient to secure the support of our members and would in fact still amount to a two-tier system of pay for consultants working side-by-side and doing exactly the same work with the same level of responsibility.
“The Government ignored the fundamental principle of equal pay for equal work and now must deal with the consequences of up to 300 vacant consultant posts across the Irish hospital system. A number that is set to rise over the coming months.”
In September, the Government moved to go part, but not all, of the way towards reversing a highly controversial 30 per cent pay cut put in place for all hospital consultants appointed after October 2012.
The decision by members of the IMO to reject the new pay offer came despite a last minute intervention by Mr Varadkar on Tuesday night in which he promised to support pay parity for newly-appointed hospital consultants as part of any new public service pay deal to succeed the Haddington Road agreement.
However, he said the revised pay rates for senior doctors proposed by the Labour Relations Commission “cannot be improved on”.
The Irish Hospital Consultants Association, the other main organisation representing senior medics, was not invited to take part in the recent talks that led to the emergence of the new pay offer on the basis that it had not signed up to the Haddington Road agreement.
Mr Tweed said the ballot result “ must be a wake up call for the Minister for Health and the HSE”.
“We should be appointing highly trained Irish doctors to these (vacant consultant) posts and not effectively forcing them to work abroad in hospitals where they are valued more and can deliver care in a properly structured and resourced environment.”
He said the Minister should now sit down with the IMO to reconsider the options.
“The unilateral pay cut of 30% imposed on new entrant consultants has caused an inequity and manpower crisis which has gone on too long without a credible solution being put forward by the health service management. If we lose this generation of consultants we may never replace them and our health services will be much the poorer for decades to come.”
Following the 30 per cent pay cut introduced in autumn 2002, medical organisations forecast that it would lead to a brain drain among doctors.
Last year the HSE accepted that it was having difficulty in recruiting and retaining hospital consultants on the salary rates on offer.
In his comments on Tuesday, Mr Varadkar said the pay scales being offered to new entrant consultants ranging from €125,000 to €190,000 represented “a very good salary by any comparison”.
Strategic Banking Corporation of Ireland (SBCI) will provide small business loans in Ireland
IRISH AND GERMAN GOVERNMENTS SIGN OFF ON DEAL GIVING €800 MILLION TO STRATEGIC BANK
German finance minister Wolfgang Schauble and his counterpart Michael Noonan signed off on today’s deal.
Representatives of the Irish and German governments have formally signed off on the long awaited release of cash to fund cheap loans for small business.
The Strategic Banking Corporation of Ireland (SBCI) will have an initial €800 million to loan to small and medium-sized enterprises to support expansion and job creation.
German state bank, KFW has committed €150 million to the project under a deal betweenthe two governments, the European Investment Bank is providing €400 million with the balance coming from the Republic’s National Pension Reserve Fund.
The Minister for finance, Michael Noonan, his cabinet colleague, Brendan Howlin and German opposite number,Wolfgang Schauble, representatives of the EIB, pension reserve fund and KFW, formally signed off on the deal today.
Mr. Noonan said he expected that the first loans would be made by the end of this year. “We have big plans for the SBCI and it will be a key source of funding for years to come,” he added.
“The legislatoin which established the SBCI allows for up to €5 billion to be made available to SMEs over the next five years.”
Stroke experts update prevention guidelines
Tools for preventing strokes include a healthy diet, home blood pressure monitoring and an online stroke-risk estimator, according to updated guidelines issued Wednesday by a leading heart health organization.
Together with traditional measures like smoking cessation aids, medications and surgeries, the updated recommendations can help people substantially reduce the risk of stroke, said Dr. James Meschia, who led the group that wrote the new guidelines for the American Heart Association/American Stroke Association.
“(Stroke is) not like one of those many conditions we have that there is no way to prevent it,” Meschia of Reuters Health said today.
About 796,000 U.S. adults have a stroke each year, the group writes in the journal Stroke. More than three quarters of these are first-time strokes.
The most common form of stroke occurs when blood flow is blocked in part of the brain, usually by a clot. Another form happens when a blood vessel breaks, hemorrhaging blood into the brain.
Nationally, strokes are the fourth leading cause of death. People who do not die from strokes may be left immobile and dependant on others for care.
“Clearly treating stroke is very difficult,” said Dr. Gregory Albers. “If you can prevent the stroke, it’s much better,” added Albers, who was not part of the guidelines group but directs the Stanford Stroke Center in California.
A 2010 study found that 90 percent of stroke risk is tied to risk factors, such as high blood pressure, overweight and smoking. While controlling those factors won’t eliminate stroke risk, it can substantially reduce it, said Meschia, who is also chair of neurology at the Mayo Clinic in Jacksonville, Florida.
The guidelines, which were last updated in 2011, focus on what can be done to prevent a first-time stroke.
“Some of it isn’t as new because it’s pulling together guidelines from other areas,” said Dr. Andrew Russman, who also wasn’t involved in updating the guidelines but is a stroke expert from the Cleveland Clinic in Ohio.
For example, the new guidelines recommend use of an online tool that estimates a person’s risk of stroke over the next 10 years based on race, gender, age, cholesterol, blood pressure, diabetes and smoking. (More information is available here: bit.ly/1uGpcMK.)
The tool was announced in conjunction with other guidelines last year and sparked controversy (see Reuters story of Nov 18, 2013 here: reut.rs/102ieol). Some doctors feared it would put too many people on cholesterol-lowering statin drugs.
The updated guidelines say statins should be used in addition to diet and exercise among people with a high risk of stroke over the next 10 years.
The guidelines also recommend new blood-thinning medications to reduce the risk of stroke among people with atrial fibrillation, an abnormal heart rhythm that can cause blood clots.
Meschia said the newer medications require less monitoring than older blood-thinners and may have other advantages, such as a reduced risk of brain bleeds.
“From that point of view – at least for the general population with atrial fibrillation at risk for stroke – they present a new option,” he said.
The guidelines also advise that people cut back on sodium and consume more potassium to lower blood pressure, and they recommend either a Dietary Approaches to Stop Hypertension (DASH) diet or a Mediterranean-style diet.
Mediterranean-style diets include a lot of fruit, vegetables and whole grains as well as fish, olive oil and nuts, but limit unhealthy fats. Mediterranean-style eating has been linked to lower risks of heart disease – possibly through reduced blood pressure.
“Clearly blood pressure – for stroke – is the number one risk factor,” Albers said. “A lot of the stroke specialists like to see blood pressure down to 120 over 80.”
Meschia agreed and said the new guidelines also recommend that people monitor their own blood pressure – not just wait for it to be measured at the doctor’s office.
“If you had to do one thing and do one thing only, it’s know your pressure and keep it down,” he said.
Russman said the risk factors addressed by the new guidelines are important and controlling them early enough may prevent strokes.
“I think it stressed the importance of eating a healthy diet – like a Mediterranean diet – and the benefit of regular exercise and follow up with a primary care physician to identify problems early when they arise, so we can initiate lifestyle and medication interventions early to prevent future problems,” Russman said.
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