Apple reports €63.5bn profit at main Irish subsidiary

iPhone group does not disclose Irish corporation tax charge but it will have come to €8bn at headline 12.5% tax rate

Tech giant Apple saw profits at its main Irish subsidiary rise to $69.3 billion (€63.5 billion) last year.

The figure is up 2 per cent on the previous year and means Cork-based Apple Operations International Ltd and its subsidiaries was delivering daily pretax profits of $189.87 million over the 12 months to September 24th, 2022.

Apple Operations International is registered at the company’s Holyhill campus in Cork and covers most of Apple’s non-US subsidiaries.

The company acts as a holding company for a number of Apple subsidiaries. It manufactures and develops everything from the company’s iPhone and iPad products to Mac computers.

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Sales at the group were 5.5 per cent – or $11.69 billion – higher last year at $222.75 billion.

The directors state that the group has international operations with sales outside Ireland representing a majority of the group’s net sales.

Accounts lodged recently with Companies Office show the business paid dividends of $20.7 billion to Apple last year, down on the $25.3 billion payout in 2021. The accounts note that those dividends are subject to US tax.

The company incurred a corporation tax charge of $11.08 billion last year across a number of countries where Apple operates, excluding US-based taxes. The figure was down marginally on the $11.57 billion tax charge for 2021.

The firm paid corporation tax of $7.69 billion. The business’s total provision for corporation tax of $11.08 billion takes account of deferred tax of $3.29 billion. The €7.69 billion paid in fiscal 2022 is a 73 per cent increase on the €4.44 billion cash paid in corporation tax by the business in the prior year.

The accounts don’t disclose precisely how much corporate tax was paid in Ireland where Apple is one of a handful of large multinationals driving an exceptional surge in corporation tax revenues, but they note that a 12.5 per cent corporate tax charge would have resulted in corporation taxes of $8.66 billion (€7.9 billion).

The filing does not say in which countries corporation tax was paid but the greatest share is likely to have been paid here, where the company is based.

The accounts refer to the successful appeal by Apple and Irish Government against the European Commission decision six years ago that the iPhone-maker owed Revenue €13.1 billion in back taxes, plus interest of €1.2 billion. In July 2020, Europe’s second highest court ruled that the Government didn’t give Apple any State aid.

The commission has since appealed that ruling to the Court of Justice of the European Union.

A note attached to the accounts states that Apple may request approval from the Irish Minister for Finance “to reduce the recovery amount for certain taxes paid to other countries”. The note states that, as of September 24th last, the adjusted recovery amount was €12.7 billion, excluding interest.

The €12.7 billion plus interest is funded into escrow where it will remain restricted from general use pending the conclusion of all legal proceedings.

The US tech giant employed 56,639 people in Apple Operations International and its subsidiaries last year – a 4,076 increase on the 52,563 employed in September 2021. Some 6,000 of those employees are based in Ireland.

Staff costs totalled $6.33 billion and that included share-based compensation of $1.39 billion.

The business’s shareholder funds at the end of September last amounted to $97.64 billion compared with $58.77 billion at the end of September 2021. Cash funds increased from $16.8 billion to $17.48 billion.

Gordon Deegan

Gordon Deegan

Gordon Deegan is a contributor to The Irish Times