http://www.guardian.co.uk/technology/2013/may/29/apple-tax-profits-ireland-cork
Apple's Irish operation has a multi-billion dollar profit – and a tiny tax bill. How does it do it?
The investigation found:
• Apple's Cork site employs large numbers of foreign workers, many employed in call centres dealing with technical-support queries raised in their home countries. Recent Cork job adverts show vacancies for a Spanish payroll analyst, Nordic customer relations adviser, Norwegian Apple specialist, Russian fraud analyst and a German Agreement admin adviser.
• Staff at what Cook calls "our campus in Cork" earned less than the average for Apple, though Harvard professor Stephen Shay has calculated that 2011 profit per employee at the Cork site was more than $9m.
• Although Steve Jobs made Cork his first European base in 1980, most manufacturing operations left Cork years ago. Printed circuit-board production went to Indonesia in 1998, while iMac assembly transferred to Wales a year later.
• Most Apple products destined for all markets outside of the Americas are manufactured by Foxconn in China on orders from Cork. Almost all of them never touch Ireland, being shipped directly to local distributors and retailers in Europe, the Middle East, India, Africa, Asia and Australia.
• Apple has been able to draw a secrecy veil over its Irish operations by making extensive use of unlimited companies, which are not required to file company accounts.
• Billions of dollars of profit pouring into Apple's Irish coffers each year are managed by Apple's Nevada-based investment subsidiary Braeburn Capital, making it larger than any US hedge fund. Cash reserves are held in banks in New York with not a penny in Ireland.
• Main accounting records for at least one of these companies are held in Austin, Texas. Meanwhile, notes of board meetings are taken by Apple's California-based general counsel Gene Levoff and sent to a law firm in Ireland to be typed up as formal minutes.
• Auditors to Apple companies are Ernst & Young, the accountancy firm that also audits Google, Facebook and Amazon – each of which have also elected to set up substantial operations in Ireland. E&Y did $6bn of tax advisory work last year.
