Corporations with multi national operations routinely undertake international tax planning to try to reduce their overall tax burden. National tax authorities have been targeting international operations for some time now. Transfer pricing audits by CRA are routine and have as their purpose ensuring that prices paid by a Canadian corporation to an offshore affiliate are at fair market value. In this case the EU has accused Ireland of state assistance to Apple and ordered Apple to repay some 14 billion Euros of taxes. This ruling is being challenged by both Ireland and Apple, which both say that the tax paid by Apple was in accordance with existing Irish tax laws.
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