The European Commission has concluded that Ireland granted undue tax benefits of up to €13 billion to Apple. This is illegal under EU state aid rules, because it allowed Apple to pay substantially less tax than other businesses. Ireland must now recover the illegal aid.
Following an in-depth state aid investigation launched in June 2014, the European Commission has concluded that two tax rulings issued by Ireland to Apple have substantially and artificially lowered the tax paid by Apple in Ireland since 1991. The rulings endorsed a way to establish the taxable profits for two Irish incorporated companies of the Apple group (Apple Sales International and Apple Operations Europe), which did not correspond to economic reality: almost all sales profits recorded by the two companies were internally attributed to a “head office”. The Commission’s assessment showed that these “head offices” existed only on paper and could not have generated such profits. These profits allocated to the “head offices” were not subject to tax in any country under specific provisions of the Irish tax law, which are no longer in force. As a result of the allocation method endorsed in the tax rulings, Apple only paid an effective corporate tax rate that declined from 1% in 2003 to 0.005% in 2014 on the profits of Apple Sales International.
This selective tax treatment of Apple in Ireland is illegal under EU state aid rules, because it gives Apple a significant advantage over other businesses that are subject to the same national taxation rules. The Commission can order recovery of illegal state aid for a ten-year period preceding the Commission’s first request for information in 2013. Ireland must now recover the unpaid taxes in Ireland from Apple for the years 2003 to 2014 of up to €13 billion, plus interest.
In fact, the tax treatment in Ireland enabled Apple to avoid taxation on almost all profits generated by sales of Apple products in the entire EU Single Market. This is due to Apple’s decision to record all sales in Ireland rather than in the countries where the products were sold. This structure is however outside the remit of EU state aid control. If other countries were to require Apple to pay more tax on profits of the two companies over the same period under their national taxation rules, this would reduce the amount to be recovered by Ireland.
However, Irish authorities have vowed to fight the finding, and the U.S. government has disputed the EU’s position.
“Ireland’s position remains that the full amount of tax was paid in this case and no state aid was provided,” the Irish government said in a statement. “Ireland does not do deals with taxpayers.”
Apple and other major U.S. firms including Google and Microsoft hold stockpiles of what’s known as indefinitely reinvested foreign earnings, or revenue not subject to U.S. corporate income tax, outside the U.S. The 10 firms with the largest holdings collectively have $724 billion in this revenue outside the U.S., a USA TODAY report found.
The EU has been investigating possible tax avoidance by multinational firms since June 2014. Under current EU rules, member countries cannot give aid that grants companies or sectors an unfair advantage.
A ruling by the European Commission in October that a tax arrangement between Starbucks and the Netherlands was illegal is currently on appeal to the EU General Court, as is a similar ruling against Fiat in Luxembourg. An EU investigation into tax agreements between Amazon and Luxembourg is still awaiting a final decision.
Volkswagen Group, Toyota, and Renault-Nissan-Mitsubishi Alliance Lost $104.5bn in Revenue in 2020
Automakers Lost $104.5 Billion in Combined Revenue in H1 2020
Automakers had a rough start to 2020, with global auto production, and sales slumped amid the coronavirus outbreak. Supply chain disruptions, factory closures, and sales drops had a massive impact on the largest automobile manufactures, causing a sharp fall in their revenues.
According to data presented by StockApps, the Volkswagen Group, Toyota, and Renault-Nissan-Mitsubishi Alliance, as the leading automobile manufacturers based on global sales, lost $104.5bn in combined revenue in the first half of 2020.
Volkswagen Group Revenue Plunged by $34.5bn, the Biggest Drop in 2020
The world’s largest automobile manufacturer, the Volkswagen Group sold the most cars in 2019, delivering 10.2 million sedans, sport-utility vehicles, and compact cars under its top passenger car brands, and almost 734,000 trucks in its three commercial vehicle brands. Statista data also revealed the German automaker hit a 25.4% market share based on new car registrations in Europe as of October.
Although the company managed to reduce the effects of COVID-19 in the first half of the year, the H1 2020 financial report still revealed severe losses. Between January and June, the Group’s sales revenue plunged by $34.5bn to $114bn, the heaviest fall among the top three automakers.
The COVID-19 outbreak caused a 27% drop in vehicle deliveries and an adjusted operating loss of $940 million in the first half of 2020, down from an $11.8bn adjusted operating profit in the year-earlier period, forcing the German automaker to slash its dividend. The Yahoo Finance data also revealed the Volkswagen Group market cap dropped by 17% in 2020, falling from $98.1bn in December 2019 to $80.8bn last week.
Toyota Motor Corporation, the world’s second-largest car producer, sold 10.74 million vehicles in 2019. With 7.9 million cars sold between January and June, 100,000 more than VW Group, the company could become the leading automaker in 2020 if COVID-19 is contained in its most important markets, Japan and the United States.
In fiscal 2020, ended on March 31st, 2020, the Toyota sales revenue dropped by $2.9bn or 1.1% to $290bn. However, the Q1 FY 2021 results, for the period between April and June 2020, revealed a 40.4% drop in revenue and the smallest quarterly profit in nine years as the coronavirus pandemic halved its car sales. Statistics show the revenue of the Japanese automaker plunged by $29.7bn YoY in the second quarter of 2020, with a total loss in the first half of 2020 reaching $32.7bn.
The auto giant expects coronavirus to deliver a major blow to earnings and sales in the fiscal year ending March 2021, with net profit forecast to plunge 64% year-over-year to $6.97bn.
Renault-Nissan-Mitsubishi Alliance Suffered a $37.3bn Loss
With 10 million vehicles sold in 2019 and 6.3 million in the first half of 2020, the Franco-Japanese Alliance, Renault-Nissan-Mitsubishi, ranked third on the list of the top-selling car manufacturers.
Nevertheless, the COVID-19 outbreak severely affected their business. The Renault Group suffered a massive downturn for the first half of 2020. Between January and June, the company reported $21.8bn in sales revenue, a $12.5bn or 34% plunge year-over-year.
Sales figures were also down for the period, with the Renault Group suffering a 34.9% plunge globally and 41.8% in Europe, the second-worst hit region after the Americas. Nissan’s sales dropped by 47.7% globally and 33.7% in its home market of Japan.
Mitsubishi Motors reported a $12.6bn revenue loss in the fiscal year ended March 31st, 2020. The downturn continued in the Q1 of the fiscal year 2021, with revenues falling to $25.5bn, a 32% plunge year-over-year. The Japanese multinational automotive manufacturer suffered a total loss of $24.8bn in the first half of 2020, while its market cap halved reaching $2.98 bn last week.
Statistics show the Franco-Japanese Alliance lost a total of $37.3bn in sales revenue in the first half of 2020.
Oil Steadies, But Outlook Gloomy as Coronavirus Cases, Supply Grow
Oil prices eked out small gains on Tuesday after sharp losses, but sentiment remained subdued as a surge in global coronavirus cases hit prospects for crude demand while supply is rising.
Brent crude was up 43 cents, or 1%, at $40.87 a barrel. U.S. oil gained 43 cents, or 1.1%, at $38.99 a barrel. Both contracts fell more than 3% on Monday.
A lack of progress on agreeing a U.S. coronavirus relief package added to market gloom, although U.S. House of Representatives Speaker Nancy Pelosi said on Monday she hoped a deal can be reached before the Nov. 3 elections.
A wave of coronavirus infections sweeping across the United States, Russia, France and many other countries has undermined the global economic outlook, with record numbers of new cases forcing some countries to impose fresh restrictions as winter looms.
“We think demand from this point onwards is really going to struggle to grow. COVID-19 restrictions are all part of that,” said Commonwealth Bank of Australia (CBA) commodities analyst Vivek Dhar.
CBA expects U.S. oil to average $38 and Brent to average $41 in the fourth quarter this year.
Prices got some support from a potential drop in U.S. production as oil companies began shutting offshore rigs with the approach of a hurricane in the Gulf of Mexico.
Saudi Arabia’s Energy Minister Prince Abdulaziz bin Salman said on Monday the worst is over for the crude market.
But his comment contradicted an earlier remark from OPEC’s secretary general, who said any oil market recovery may take longer than hoped as coronavirus infections rise around the world.
Meanwhile, Libyan production is expected to reach 1 million barrels per day (bpd) in the coming weeks, the country’s national oil company said on Friday, a quicker return than many analysts had predicted.
That is likely to complicate efforts by the Organization of the Petroleum Exporting Countries (OPEC) to restrict output to offset weak demand.
OPEC+ – made up of OPEC and allies including Russia – is planning to increase production by 2 million bpd from the start of 2021 after record output cuts earlier this year.
An analyst survey by Reuters ahead of data from the American Petroleum Institute on Tuesday and the U.S. Energy Information Administration on Wednesday estimated that U.S. crude stocks rose in the week to Oct. 23, while gasoline and distillate inventories fell.
Nigel Farage Urged to Highlight Perils of DIY Investing
Nigel Farage appears to be advocating a DIY approach to investing – and this could be “monumentally risky” for inexperienced investors, warns the CEO of one of the world’s largest independent financial advisory and fintech organisations.
The warning from Nigel Green, chief executive and founder of deVere Group, comes as a daily finance-orientated newsletter from the team of the Brexit Party leader and political activist urges its readers to “tell us about your successes by going it alone – leaving the money men and middlemen by the side of the road…”
Mr Farage’s email is provided for correspondence.
Mr Green comments: “Successful DIY (Do It Yourself) investing can be possible, but for most people it is not recommended – indeed, it could be a costly and traumatic accident waiting to happen.
“Going it alone can be monumentally risky for inexperienced investors as the complexities involved can sink their portfolios.
“Perhaps this is why around two-thirds of wealthy individuals have a professional financial adviser of some sort, according to new independent research from the University of Toronto.”
He continues: “I would urge anyone who extols the virtues of a DIY approach to investing to also underscore the risks and potential pitfalls to be avoided.”
A pro will help you make the best investment decisions in five key ways, says Nigel Green.
“First, helping you to diversify a portfolio. Spreading money around is vital to curb risk. However, it must be used correctly – diversification will only add real value if the new asset has a different risk profile.
“Second, investing with a plan: Unless you have a sound plan, you’re gambling, not investing.
“Third, avoiding emotional decisions. Overly emotional decisions can prove deadly when it comes to investments because they are blighted by prejudices and biases.
“Fourth, regularly reviewing your portfolio: Investments need to be consistently reviewed to ensure they still deserve their place in the portfolio and that they are still on track to reach your long-term financial objectives.
“Fifth, not focusing excessively on historical returns: The future investment situation is likely to be different from time-aged averages.”
The deVere CEO concludes: “While investing remains almost universally regarded as one of the best ways to create, grow and safeguard wealth, considering the pitfalls of getting it wrong, it could be an expensive mistake for you and your family not to seek professional advice.”
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