C&AG: Apple tax fund's market losses and €881m gain 

Final transfer of cash from the fund to the Irish Exchequer took place on May 9, 2025

In September last year, the European Court of Justice ruled that Ireland had granted unlawful state aid to Apple over several years, for which Ireland had to recover more than €13bn from the tech giant. Picture: Dan Linehan

The Comptroller and Auditor General (C&AG) has detailed the performance of the Apple escrow fund in the years leading up to the final judgement of the case.

In September last year, the European Court of Justice ruled that Ireland had granted unlawful state aid to Apple over several years, for which Ireland had to recover more than €13bn from the tech giant.

The escrow account which held the disputed funds was agreed to have a low risk appetite, and was therefore invested in highly-rated euro-denominated fixed-income securities — such as sovereign and corporate bonds, or held as cash and cash equivalents.

The report said the value of the fund decreased each year from 2018 to 2022 inclusive.

This was, in part, due to third-party adjustments in 2019 and 2021. These adjustments added to €455m and were related to situations where Apple was required to pay taxes in another jurisdiction in respect of a portion of the profits, subject to the state aid decision.

In addition to this, the fund’s falling value in this period was also underpinned by declines in the market value of securities. Between 2018 and 2021, the fund lost a total of €172m in value, which reflected the negative interest rate environment and negative yields at the time.

In 2022, the European Central Bank raised interest rates, which resulted in a decline in market value of €253m as prices fell and yields increased across global fixed-income markets.

In later years, however, the value of the fund began to rise significantly.

Between 2023 and 2025, the net assets of the fund increased by €881m, which was driven by a higher interest rate environment, with the increased income mainly due to reinvesting in assets at higher yields.

In September 2024, total assets of €14.17bn were held in the escrow fund, of which around 45% was invested in financial assets and 55% held in cash and cash equivalents.

After the European Court of Justice’s ruling in September last year, Revenue issued tax assessments amounting to €11bn between October and December 2024. The remaining assets, valued at €1.7bn, were issued in January this year, with a total of €12.7bn being issued.

Following the payment of fees and operational expenses, the balance of the fund, which amounted to €1.567bn, was transferred directly to the central fund of the exchequer, as non-tax receipts. The transfer took place through several cash transfers in 2025, with the final transfer taking place on May 9, 2025.

The fund was closed with a zero balance with effect from May 13, 2025.