[valo403]

Originally Posted by Five-hole

US: Apple, we're going to tax you 25% (or whatever the US corporate tax rate is).

Apple: No problem. We don't have any income here anyway because our licenses for all our stuffz are in Ireland and we gotta pay them all our profits!

US: That's not fair, you're overpaying! Affiliates have to pay a reasonable arm's length price for services or goods.

Apple: Oh, that's not our affiliate. It's this company in Barbados who pays royalties to this other company in Ireland, who pays another company in Ireland, who pays a company in the Netherlands, who pays a company in Luxembourg. Some of those are ours.

US: All of those are yours! C'mon Luxembourg, fess up.

Luxembourg, Switzerland, British Virgin Islands, Mauritius, etc.: Nope. No thanks.

Apple: Also, you can't tell us what a reasonable arm's length price is for a unique patent, so nyah nyah.

And on it goes. Rules already exist to enforce the payment of taxes way beyond what Apple is paying now. I suppose you could call it semantics and say it's still their rules that allow any of this to go down but I'm telling you there is no set of rules that any one country can enact to stop multinationals from doing what they're doing. It requires multilateral tax treaties, and it requires countries who have every desire not to cooperate in such things to sign them.

Well then I guess it's a matter of semantics, because I wasn't arguing that any of that is incorrect (actually spent a couple hours at a cross-border tax seminar yesterday). At the end of the day the outrage Congress is showing is purely a political puppet show, they know the game but are pretending that Apple is somehow fleecing Americans.