The European Commission’s (EC) investigation of Apple’s transfer pricing arrangements in Ireland has been underway for quite some time now. If the EC determines that Ireland provided state aid to the company through advance tax rulings, Apple could be responsible for paying up to ten years of past taxes.

The Investigation

In order to come to a decision regarding Apple’s tax responsibility, the EC is investigating:

• If Ireland issued advance tax rulings to reduce Apple’s tax burden
• If state aid was used in transfer pricing arrangements to determine the profits of two Apple subsidiaries

You are encouraged to meet with your international tax advisor if your business has received any advance tax ruling from an EU member state to ensure that it will be sustained in the event of EC review. For more information, read our article, “EC Probe Could Have ‘Material’ Implications for Apple”.