The Lure Of Ireland For Global Tech Firms

Although Apple has come under the EU microscope over its tax affairs, complex corporate structures have become a common accounting tool for savvy tech firms.

The European Commission's preliminary findings show it has doubts that two "sweetheart" tax deals agreed in 1991 and 2007 between Apple (NasdaqGS: AAPL - news) and Ireland (Other OTC: IRLD - news) are compatible with the "internal market" of the European Union.

The Californian tech giant has two subsidiaries; Apple Operations Europe and Apple Operations International, which have operated in Ireland since 1980.

And it created Apple Distribution International in 2009 and Apple Operations in 2010. It has at least three other subsidiaries, which are all based on a large industrial estate in Hollyhill, County Cork.

The site employs around 4,000 people and is the biggest employer in the city of Cork.

But the issue of so-called transfer pricing, or advance pricing arrangements used to shift tax liabilities to lower tax areas, has become a key issue for US politicians, the EU, the G20 and the Organisation for Economic Co-operation and Development

Rather than maximising profit in each country, transfer pricing can give a financial incentive to record high profit in low tax areas and low profit in high tax jurisdictions.

A Congressional Research Service report last year found that US multinationals reported earning 43% of their overseas profits in 2008 from Bermuda, Ireland, Luxembourg, the Netherlands and Switzerland.

This despite low levels of investment and domestic sales in those five locations.

It cited academic research indicating that the loss of tax to the US Treasury was between $30bn (£18bn) to $90bn (£55bn) annually.

But companies deny wrongdoing, and say they are simply working within existing legislation in the territories they operate in.

The issue has recently shot up the political agenda, and prompted campaigns from pressure groups such as UK Uncut.

Other US companies' tax structures have been highlighted by politicians, such as Westminster's Public Accounts Committee (PAC), including online retailers Amazon, Google (Xetra: A0B7FY - news) and even coffee chain Starbucks.

Other tech companies also operate tax structures in Ireland - Google has at least three registered companies in Ireland. Microsoft (NasdaqGS: MSFT - news) has several more and first set up an Irish subsidiary in 1979.

Both Google and Facebook (NasdaqGS: FB - news) use a loophole known as the "Double Irish", which allows them to reduce their effective tax rate well below the official 12.5% corporate rate.

Twitter UK has no Britain-based directors and answers to Twitter International Company in Dublin.

London games firm King Digital Entertainment (NYSE: KING - news) , maker of the Candy Crush Saga, is based in Ireland, listed in New York, but with its revenue-raising games websites based on the Mediterranean island of Malta.