Apple Irish arm put aside €8.2bn for corporation taxes last year

Figures suggest Apple’s tax provision could make up a large proportion of the near €24bn paid to the Irish exchequer by all corporates in 2023, but experts say it cannot be presumed Apple paid all money it set aside

Last year, Apple's Irish arm paid a dividend of €86.1bn to its parent company. Picture: PA

Apple’s main Irish subsidiary had made provisions to pay $8.8bn (€8.2bn) at the Irish corporation tax rate of 12.5% last year, new accounts show.

The figures come from Apple Operations International, or AOI, an Irish-based holding company that includes most of the tech giant’s operations around the globe, except for its massive operations in North and South America. The figures are for the 12 months to the end of September. 

On the face of it, the figures suggest that Apple’s tax provision for 2023 could make up a significant proportion of the almost €24bn total paid to the Irish exchequer by all corporates last year. 

However, experts say that it can not be taken as read that Apple paid all of the €8.2bn it set aside in provisions for corporation taxes to the Irish Government. Multinationals based in Ireland, including Apple, account for the lion's share of all corporation tax revenues but the individual amounts the companies pay is kept secret from the Irish public. 

The Irish accounts also revealed that the value of the Apple escrow fund has decreased by approximately €400m since it was established in 2016 after the EU Commission accused Ireland of giving Apple favourable tax terms. 

The recovery amount was initially calculated at €13.1bn plus €1.2bn in interest but as of September 30 last year, the fund was valued at €12.7bn, excluding interest.

The case is still working its way through the courts, with a final decision from the European Court of Justice expected later this year. 

According to the accounts, the company saw total sales of $218.9bn (€202.9bn) in 2023 — a slight decrease from the $228bn recorded in 2022.

The company said that income before tax for 2023 came to just over $71bn (€65.8bn), an increase from $69.3bn last year. It said net profit for the year came to $38.6bn (€35.8bn).

Enhanced dividend

In addition, the Irish subsidiary paid a dividend of $92.9bn (€86.1bn) to its ultimate parent company Apple, up from the $20.7bn paid in 2022. This enhanced dividend was as a result of a build-up in retained earnings over the past couple of years.

This comes as Apple faces investigations on both sides of the Atlantic into its business practices, with the US alleging the company is violating antitrust laws by blocking rival companies from accessing hardware and software features on its popular devices.

In Europe, the company is facing probes about whether it is complying with the region’s Digital Markets Act, with investigations focusing on the firm’s new fees, terms, and conditions for app store developers.

In the accounts, the company identifies changing laws and regulations worldwide, which includes antitrust action being taken by governments, as one its primary risks.

The company said that “compliance with these laws and regulations is onerous and expensive” and that investigations in Europe could result in “significant fines”.

It also warned that antitrust investigations and resulting legal proceedings could have a “materially adverse impact on the group’s business”.

In regards to the EU Digital Markets Act, Apple said it expects to make further changes to its App Store to comply with the legislation. The statement was prepared before the act came into effect on March 6.