Re: Penalties?
Apple uses a different scheme, in Ireland rather than Belgium.
Apple Operations International is registered and tax resident in Ireland. It pays money to Apple Investments International which is registered in Ireland, but controlled from Texas. It isn't tax resident in Ireland because no activity takes place there, and it isn't tax resident in Texas/USA because it is registered in Ireland, so pays no tax anywhere in the world. This is known as the "Double Irish" loophole.
Biting the hand that feeds IT
