The accompanying table shows the profitability of Apple’s NZ operations, which are run from Sydney and the parent company in California.
It appears that a large proportion of Apple’s sales in this country — from a tax point of view — go through the Irish head office to Australia and then across the Tasman.
Profit margins and tax provisions are very low in New Zealand because Apple wants to account for most of its international profits through its tax-exempt Irish head office.
One of the clear conclusions from this is that Apple would have had far higher earnings and paid far more tax in New Zealand if it wasn’t for the Irish head office structure.
Therefore countries that were supplied through the Irish head office have a stronger claim to the €13b plus interest than the Irish government because only the cash – not the physical goods – passed through Ireland.
In view of this there is a strong argument that NZ – Australia and other governments should make a claim on the €13b if the EU decision is upheld by the courts.