An unusual global tax structure, Apple Inc (AAPL.O: Quote) has maintained a multi-billion dollar profit in the Irish subsidiary to pay little or no tax of any government, the Senate report said on Monday that the company's offshore tax structure.
In the 40-page memorandum released a day before Apple CEO Tim Cook plans to testify in Congress, the Senate Permanent Subcommittee identified three subsidiaries investigation, they were incorporated into Irish, or in the United States there is no "tax residence" company executives, the management of these companies.
Main subsidiaries, holding companies, including Apple's retail stores, in the whole of Europe in the past five years, did not pay any corporate income tax.
A subsidiary of a Cork, Ireland, mailing address, received $ 29.9 billion dividend from the lower levels of offshore Apple related companies from 2009 to 2012, including Apple's worldwide total net profit of 30%, the report said.
"Apple has the difference between the tax resident in Ireland and the United States rules," the report said.
Apple said in a review posted online on Monday, it does not use "tax gimmick." It said, its subsidiaries "Apple operating international presence in Ireland will not reduce Apple's U.S. tax liability, the company will pay more than $ 700 million in fiscal year 2013, the United States taxes.
Subcommittee staff said on Monday that Apple did not violate any law, and to cooperate fully with the investigation.
Consult the Code overhaul
Tuesday's hearing will be held for the second time, Democratic Senator Carl Levin of Michigan and chairman of the subcommittee, to get rid of the weakness of the U.S. corporate tax law. Levin in Congress seek to overhaul the code.
Global Legislators are closely review the taxes paid by multinational corporations. In the UK, Google faced with the investigation of the regulatory authorities in their own tax policy, and Hewlett-Packard (HPQ.N) and Microsoft (MSFT.O: Quote) is called to Capitol Hill to answer questions in their own practice.
The company must pay 35% of the top U.S. foreign profits of the corporate income tax, but it was not until these profits into the United States from abroad. This exception is known as offshore income postponed.
Apple said in testimony submitted before Tuesday's hearing, any tax reform should help to reduce the corporate income tax rate, regardless of income, the elimination of tax expenditures, and implemented a "reasonable tax foreign exchange earnings, to allow free movement of capital, returning to the United States. "
"Apple recognizes other improvements in the corporate income tax system in the United States may increase the company's revenue," it said.
Large U.S. companies improve their offshore profits by 15% last year to a record $ 1.9 trillion, to avoid massive tax foreign profits, according to research firm audit analysis.
Tax audit
The report said that Apple also uses the two traditional offshore tax avoidance typical multinational tax avoidance strategies.
Multinational value of goods and services across international borders, from one business unit to another. Known as "transfer pricing", these moves often try to reduce the cost of global tax.
Apple's a prominent tax structure defects, Congress corporate tax law in the United States can effectively closed the loophole used by many U.S. multinationals, "Subcommittee Republican, Senator John McCain of Arizona, in a statement on Monday said.
Levin announced that he would retire at the end of 2014, in February introduced legislation to close tax loopholes. In a news conference Monday, Levin said, his bill passed by Congress independent of any broader tax reform push.
Subcommittee Republicans, McCain's joint news conference, said he would co-sponsor the Levin bill, Republican support for the bill. He called Apple's tax practices "shocking, (a) it is really outrageous plan."
The House of Representatives has introduced similar legislation.
The government taxes the IRS and Treasury officials also plan to testify before the Subcommittee on Tuesday.
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