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Apple’s bond issue (01 May 2013)


clearmurk

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Apr 27, 2012
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3,019
There I was, ready to put finger to keyboard, and whoosh, the thread disappeared. Just like funds flowing though the double Dutch Irish sandwich.

Apple sells $17 billion in bonds in record deal - RTÉ News

According to the article, Apple has so much money deposited overseas, that it makes sense for it to borrow on the markets, rather than repatriate these funds which would then be subject to US federal tax.

It raised the funds in just one day, and apparently was offered some 50 billion dollars in total (Bloomberg West).

For me, the significance of this is the further evidence of the financial asset bubble which has been created in the attempt to save the banks, with large amounts of funds sloshing around the financial markets looking for a home. And yes, this is in the US, but we are by now well acquainted with how the international markets are interlinked.

Saving the banks has saved the markets alright, but with still little sign of percolation through to the little people of Europe.

Big money rules.

<Mod> Posts have been moved to this thread from here. </Mod>
 
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stopdoingstuff

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Feb 26, 2011
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The real major tax dodge in international commerce, other than transfer pricing, is the ability of companies to treat their intellectual property as separable intangible assets that belong to one branch of the company, and then charge other branches of the same company a massive royalty fee for the exploitation of those assets. The royalty fee is deductible from the profits of the various international branches, which reduces their taxable incomes, and then flows to some tax haven somewhere. Fkrs.
 

emulator

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Oct 20, 2010
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The real major tax dodge in international commerce, other than transfer pricing, is the ability of companies to treat their intellectual property as separable intangible assets that belong to one branch of the company, and then charge other branches of the same company a massive royalty fee for the exploitation of those assets. The royalty fee is deductible from the profits of the various international branches, which reduces their taxable incomes, and then flows to some tax haven somewhere. Fkrs.
Also.

Some manufacturing MNCs get orders for certain items. Large orders that are taken by their sites in a Country with favourable CT. These sites could never fulfil these orders due to their small capacity so, they sub it out to the parent MNC.

So, massive orders coming in through one door and out the other with the local site doing very little.... some of it being done by Jobbridge people.... after a good few rounds of redundancies.

None of it illegal but the Government seem happy enough with it.
 

YouKnowWhatIMeanLike

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Apr 13, 2011
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Also.

Some manufacturing MNCs get orders for certain items. Large orders that are taken by their sites in a Country with favourable CT. These sites could never fulfil these orders due to their small capacity so, they sub it out to the parent MNC.

So, massive orders coming in through one door and out the other with the local site doing very little.... some of it being done by Jobbridge people.... after a good few rounds of redundancies.

None of it illegal but the Government seem happy enough with it.

are these orders recorded in the GDP statistics for Ireland?
 

stopdoingstuff

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Feb 26, 2011
Messages
22,897
Also.

Some manufacturing MNCs get orders for certain items. Large orders that are taken by their sites in a Country with favourable CT. These sites could never fulfil these orders due to their small capacity so, they sub it out to the parent MNC.

So, massive orders coming in through one door and out the other with the local site doing very little.... some of it being done by Jobbridge people.... after a good few rounds of redundancies.

None of it illegal but the Government seem happy enough with it.
Yeah, they would be looking to charge as much of the profits to the low tax country as possible.
 

The Old Woman

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Aug 27, 2012
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1,505
The real major tax dodge in international commerce, other than transfer pricing, is the ability of companies to treat their intellectual property as separable intangible assets that belong to one branch of the company, and then charge other branches of the same company a massive royalty fee for the exploitation of those assets. The royalty fee is deductible from the profits of the various international branches, which reduces their taxable incomes, and then flows to some tax haven somewhere. Fkrs.

For clarification for myself:
What do you call transfer pricing?
 

stopdoingstuff

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Feb 26, 2011
Messages
22,897
For clarification for myself:
What do you call transfer pricing?
Where companies who are part of the same group of companies and who transact with each other work out prices for each of those transactions.
 
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