On August 30, 2016, the European Commission ordered Ireland to collect $14.5 billion plus interest in unpaid taxes between 2003 and 2014 from Apple Inc. The European Union suggested that Ireland made "sweetheart deals" with Apple in exchange for bringing more jobs into the country and concluded that these deals constituted illegal tax benefits, contrary to the European Union's prohibitions against "state aid."

Profit shifting and transfer pricing manipulation dominate the analysis of the corporate tax structure in Ireland and its position in the context of global tax policy. This note explains the European Commission's Apple decision and analyzes how this decision will affect Ireland's international relations and its law reform, so that Ireland could comply with the European Union and international tax law.

The European Commission's Apple decision helped the United States, the European Union, and Ireland start a conversation on how to work together to regulate tax evasion on a global scale. I conclude that tax system reforms on an international scale will happen in the future to combat "illegal deals" between multinational companies and specific countries.


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pp. 539-564
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