Re: Well, bears in the woods etc.
I thought the opposite was true. Apple-Ireland holds the IP but the Irish government doesn't make Apple pay tax on sales outside Ireland.
The question is whether Apple's arrangement was fair and comparable to any other corporate in the same position.
No. Two questions:
1. Was it legal under existing Eu taxation treaties and harmonization directives? While tax was never fully harmonized, partial harmonization has been part of even the earliest Eu treaties. This includes all Eu members charging VAT (with any exception being negotiated), all Eu members charging corporate tax (no exception) as well as all members charging NI and income tax to allow benefits to be transferable.
2. Was the failure of Ireland to comply with its commitments to Eu tax harmonization a form of state aid and was it deliberate and advertised to corporations in order for them to settle in Ireland. I suspect that there was at least one person in the Irish government to advertise it in the last 20 years which pretty much makes this an open and shut case outright.