The report says Apple capitalizes on a difference between US and Irish rules regarding tax residency.
In Ireland, a company must be managed and controlled in the country to be a tax resident.
Under US law, a company is a tax resident of the country in which it was established. Therefore, the Apple companies are not tax residents of Ireland nor of the US, since they were not incorporated in the US, in Apple’s view.
In its second quarter ended March 31, Apple posted its first profit decline in 10 years. Net income was US$9.5 billion, or US$10.09 a share, down 18 percent from US$11.6 billion, or US$12.30 a share, in the same period a year ago. Revenue increased 11 percent, to US$43.6 billion.