スペインでにアメリカ合衆国の情報技術企業のAppleは、アイルランドの子会社を使い脱税
Apple usa filiales sin patria fiscal
Un informe del Senado de EE UU acusa a la firma de Tim Cook de eludir el fisco con sus filiales
"Apple ha explotado la diferencia entre las normas de residencia tributaria", sostiene el estudio
DESCARGABLE Informe del Senado sobre Apple, en inglés
DESCARGABLE Defensa de Apple ante el Senado, en inglés
Apple quiere pagar menos
Sandro Pozzi Nueva York 21 MAY 2013 - 22:13 CET
Apple uses no tax country subsidiaries
A Senate report accuses U.S. firm of Tim Cook to circumvent the Treasury with its subsidiaries
"Apple has exploited the difference between the tax residence rules," says the study
DOWNLOADABLE Senate Report on Apple in English
Apple DOWNLOADABLE Defense before the Senate, in English
Apple wants to pay less
Sandro Pozzi New York 21 MAY 2013 - 22:13 CET
The Holy Grail of tax evasion . This forcefully presented Senator Carl Levin the complex structure of subsidiaries that Apple has been creating for decades outside the U.S. to avoid paying billions in taxes. He did it by exploiting loopholes in the law . A U.S. Senate investigation has shown that its practice is to concentrate the benefits in certain subsidiaries that are tax stateless , ie , who have neither office nor tax filers in any country.
Tax engineering practices are widespread among large U.S. multinationals are not exclusive and technology firms , but the Senate has taken Apple as a case study thoroughly.
The report cites that Apple negotiated with the Irish Government an application of the income tax which in practice has meant a reduction of 12% to less than 2 % , thus laying the foundation for its network of subsidiaries abroad . " But not content with that," added Levin.
The Senate identifies three subsidiaries that do not pay the Treasury or in Ireland or in the U.S.
In the case of the Cupertino firm , research is set mainly in subsidiaries in Cork ( Ireland) with tax residence is nowhere . According to U.S. law, not taxed in the U.S. because its headquarters is in Ireland , according to Irish law , is not taxable in Ireland that are managed and controlled from the United States. Apple goes down the hole.
This is the case of Apple Operations International ( AOI) , founded in 1980 , and operates as a holding company for most of Apple 's subsidiaries abroad of dividends received . Despite being domiciled in Cork, has no physical presence there or anywhere else that has or has employees . Three employees of other companies Apple are his advisers . The vast majority of board meetings are held in California, where two of the three directors reside. Although benefits achieved 30,000 million in the last four years, not even provided tax anywhere.
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Another key group company in the same situation . This is Apple Sales International ( ASI) , which posted gains of 74,000 million dollars in the last four years for which hardly taxed . In 2011, for example, 22,000 million dollars of benefit paid $ 10 million , less than 0.05% . " The issue here is not what you pay but what you do not pay ," he said Levin. With their tactics , Senator calculates that Apple is dodging the equivalent of 25 million a day in taxes.
AOI depends indirectly controlling subsidiary stores in Spain , while ASI bill most sales in the Spanish market , which the group escapes almost entirely of Spanish Hacienda billing from Irish companies without tax residency .
evade taxes
Apple uses subsidiaries have tax residence in any country, which are a kind of tax stateless persons who are not required to file a tax return .
The company leverages a loophole . It has subsidiaries in Ireland managed from the U.S.. Not taxed in the U.S. to have its headquarters in Ireland and not taxable in Ireland to be controlled from the U.S.
The two main branches of this type are Apple Sales International, from where also billed sales in Spain , Apple and International Operations , which controls the network of stores in several countries, including Spain .
Research supports that there is nothing illegal. In fact, Apple 's fiscal creativity is clearly reflected in the accounts at the end of each financial year refers to the regulator. As Professor Stephen Shay said the current system creates an "irresistible incentive" to divert profits.
Tim Cook, Apple CEO , insisted that his firm is among the corporations that pay more in taxes in the U.S. . Sen. John McCain says it might be worth in absolute terms, " but also of proportion to avoid paying more in taxes." In this regard, he noted that a company that contributes to both the wit and the economy should not follow practices " that deprive citizens of revenue."
For McCain, your tax strategy Apple got " divide the world into two: the U.S. and the rest." The aim of the debate , he said , is to shed light on these tactics. The Obama administration is opposed to reaching a temporary agreement to repatriate the body of accumulating assets abroad.
The White House, as lawmakers in Congress agree that the time to " modernize" a tax system that is also competitive for U.S. multinationals arrived. The corporate tax rate is the highest in the OECD. Although, as McCain reiterated , this should not be an excuse to look the other way against tax strategies that at least , he said, are " questionable " and "unacceptable " .
Apple has more than 100,000 million outside the U.S. . 61% of its sales are recorded abroad. Levin clinched the debate insisting that " no apology " to what they do and why multinational insists that "none should have the right to decide what taxes will pay or how many benefits will keep on tax havens ." It was his way of saying that what Apple does not pay , so he pays the rest.
Unfortunately , the tax system is not up to the Digital Age
Cook reiterated that his company pays all taxes that requires legislation in countries offering products and services. He also made it clear to the senators who do not hide their money in bank accounts in the Caribbean islands, and their employees and businesses are "real" . In his view, the problem is that " the tax system is not up to the digital age " and therefore advocated a " drastic simplification " .
"We have always believed in simple, so are our products ," he said , while suggesting that apply a tax " reasonable" profit is generated outside , many companies could repatriate and that would benefit the economy. The did not give specific figures , but said that sales in the United States should be in the 25 % and earnings generated by its activity abroad should be " a digit " .
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