No, not really

The difficulty for Noonan, Ireland and Apple is that there is now an EU Competition Commissioner who, with eyes wide open, looks at the deal Apple did and says that Ireland knowingly and wittingly assisted that outcome by allowing the existence of companies not taxable anywhere for which only they could be responsible in the scheme as a whole.

We all know where those profits should and will be taxed. In the US when and if they are repatriated.

Ritchie’s logical problem here is that he wants tax to be paid where economic activity takes place. Quite obviously the design of Apple products takes place in Cupertino. Thus that’s where the profits should be taxed in whatever manner Cupertino, or the jurisdiction around it, says they should be taxed. Which is how they are taxed.

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