We will consider the judgment carefully when it is circulated.
The Irish position has always been that Ireland does not give preferential tax treatment to any companies or taxpayers. The CJEU has found that the tax paid was insufficient and that a greater amount of taxation was required to be recovered. Ireland will of course respect the findings of the Court regarding the tax due in this case.
The judgment provides the final determination in this case and the process of transferring the assets in the Escrow Fund to Ireland will now commence in the manner prescribed in the Deed governing the operations of the Escrow Fund.
The Apple case involved an issue that is now of historical relevance only; the Revenue opinions date back to 1991 and 2007 and are no longer in force; and Ireland has already introduced changes to the law regarding corporate residence rules and the attribution of profits to branches of non-resident companies operating in the State.
Ireland is an active participant in international tax discussions and has also made necessary changes to its taxation regime as international tax rules have developed over time
