Tim Cook angry pissed upset

The European Commission has ruled that Apple is on the hook for €13 billion ($14.5 billion) in back taxes as its “sweetheart deal” to pay a lower tax rate in Ireland has been characterized as “illegal state aid”.

Apple is going to appeal the ruling and now CEO Tim Cook has penned an open letter, entitled “A Message to the Apple Community in Europe,” in which he explains Apple’s position in this case, writing he is “confident” that the huge tax bill will be reversed.

Cook opens the letter with an explainer on how late Steve Jobs established a factory in Cork, Ireland, in 1980 with 60 employees. Apple now employs nearly 6,000 people in Ireland, most of them in Cork. The Cupertino company is Ireland’s largest taxpayer and the largest taxpayer in the world for that matter.

EU Ireland Apple ruling infographic 001

“A company’s profits should be taxed in the country where the value is created. Apple, Ireland and the United States all agree on this principle,” reads Cook’s open letter.

In Apple’s case, nearly all of our research and development takes place in California, so the vast majority of our profits are taxed in the United States. European companies doing business in the U.S. are taxed according to the same principle. But the Commission is now calling to retroactively change those rules.

The “unprecedented” move on EU’s part, Cook cautioned, could have “serious, wide-reaching implications.”

Beyond the obvious targeting of Apple, the most profound and harmful effect of this ruling will be on investment and job creation in Europe. Using the Commission’s theory, every company in Ireland and across Europe is suddenly at risk of being subjected to taxes under laws that never existed.

He then went on to lambast the Commission’s ruling:

The European Commission has launched an effort to rewrite Apple’s history in Europe, ignore Ireland’s tax laws and upend the international tax system in the process. The opinion issued on August 30th alleges that Ireland gave Apple a special deal on our taxes. This claim has no basis in fact or in law.

We never asked for, nor did we receive, any special deals. We now find ourselves in the unusual position of being ordered to retroactively pay additional taxes to a government that says we don’t owe them any more than we’ve already paid.

Cook’s message can be read in full over at Apple’s website.

According to analysts who spoke with CNBC, the iPhone maker probably won’t end up paying all of its massive Irish tax bill.

In a recent interview with The Washington Post, the Apple CEO reiterated that his company did not receive preferential treatment from Ireland.

“It’s important for everyone to understand that the allegation made in the .U. is that Ireland gave us a special deal. Ireland denies that,” he said. “The structure we have was applicable to everybody—it wasn’t something that was done unique to Apple.”

“It was their law,” Cook told the paper, adding:

And the basic controversy at the root of this is, people really aren’t arguing that Apple should pay more taxes They’re arguing about who they should be paid to. And so there’s a tug of war going on between the countries of how you allocate profits. The way tax law works is the place you create value is the place where you are taxed. And so because we develop products largely in the United States, the tax accrues to the United States.

What’s you position on this topic?

Apple has certainly paid every penny it owed in taxes, but is the European Union right in calling Apple’s sweetheart deal with Ireland “illegal stated aid”?

And if so, should Apple be slapped with a multibillion ruling and what kind of message might that decision send to other U.S. companies, like Google and Microsoft (which also funnel international revenues through a complex network of European tax havens)?

Source: Apple Ireland

  • Pierre Bugeja

    I think the European union should wake up and start acting seriously and professionally. As a European, I am ashamed particularly when recently I was told that some individuals, in a particular European country, contacted the ombudsman regarding syphoning of European funds for personal purposes by politicians. I am told that the ombudsman’s response was, “The EU is too slow to act on such issues”, and that was were the complaint ended. So let us not try to be childish and envious… it is easy to climb the apply tree. But that should not be the focus. Look at how the EU funds are being (mis)managed….

    • jOn Garrett

      I think the people who made this decision have tons more knowledge about this than you, and are not blinded by brand loyalty.

      • But here’s the big irony in it all. The EU has determined that the Ireland government did something illegal. Not Apple. In fact Apple has testimony from the government claiming that they have paid everything they were ever asked to pay. Their company structure is also completely legal too. So where does this leave us? The EU has filed criminal charges against the Ireland government, but in an awe inspiring move has tried to resolve all the politicians of any wrong and lay the blame entirely at the feet of Apple.

        I’m not saying that the law shouldn’t be changed, that Apple shouldn’t have to pay more, or anything else. I’m simply stating that if what they are saying is true, than the illegal actions of a government trying to bribe companies into doing business with them over other neighbors turn out to be true; then it should be the government (not Apple) that is held to task. Going after a scape goat with deep pockets is nothing short of a shockingly greedy and devious move (since I doubt the government will take any blame for this at all).

      • jOn Garrett

        Apple was not ignorant to the facts you’ve stated, how could they be? They’re a multi billion dollar corporation and they pay millions to accountants and lawyers.

        Apple isn’t the only one so this shouldn’t just about them, Google, Microsoft, Amazon, and countless others exploit tax loopholes to avoid paying taxes. Much worse is how these corporations pay pennies on the dollar for overseas labor, get tax subsidies here in the US and still it’s not enough for them.

        If it was up to me, every US company would pay what they owe, every loophole closed and overseas cash brought back home.

      • Oh I’m sure they almost every corporation that picked Ireland for a base of operations did so exactly for that reason. It would just be good business sense.

        Here in the US for example not all states are equal in how they tax either. Delaware for instance is a very popular place for technology stat-ups to incorporate in as they offer fantastic legal systems and charge 0 corporate taxes for companies that are formed there but don’t transact business there. 0 taxes is appealing right?

        Now would you argue that the other states in the Union should be able to force Delaware to change their tax code and then force all corporations to pay back taxes on the new law?

        I know its the popular view these days to view rich people with distain, but I think of it like this. When I fill out my taxes do I try to take any deductions that I can? If I myself am willing to take legal deductions to lower my tax rates so that I don’t have to pay in everything based on my overall income then how can I turn around and point a finger at someone else and say how dare they take advantage of a legal deduction. I get excited for deductions for buying a car, education, and so on. But in its simplest form I’m using the law to reduce the amount that I owe and getting out of sending in some amount of my taxes. At the end of the day big corporations are doing the same thing. It just feels different because the numbers are so much bigger.

        If my deductions I claim on taxes are able to get me out of the equivalent of 3 days worth of income that means that I saved about $240 in taxes. If Apple saved 3 days worth of income that would amount to over $330,000,000. Both of us did the exact same thing down to the exact percentage in that example but while no one bats an eye at a lower income person saving less than $300 on taxes (or even getting money back at tax time) but everyone is horrified at Apple saving millions on taxes. I think it’s all a matter of perspective.

        Now for people that want to point out that Apple makes more so it hurts more, that’s all relative. Think of it this way. The average income in the US is a little over $50,000 a year. There are about 240,000,000 adults here as well. So if all of them manage to get out of 3 days worth of taxes (about $410) the government looses 98 billion dollars. And you and I are part of that loss (unless you never claim any deductions on taxes). Anyways just some thoughts to put this in perspective. Yes laws need to be reformed, and yes there are problems with the tax code. But if a legal system allows a deduction or a better tax rate it doesn’t mean someone is evil. It just means they are like you and me. They like a good deal 🙂


      • Pierre Bugeja

        Perhaps. But certainly, you know nothing about me….

  • William D

    As a European I think it’s about time companies like Apple stop playing the system and actually pay taxes which materially reflect their sales and profits! For one of the most valuable companies on the planet to to structure a ‘head office’ with NO employees to have an effective tax rate well below 1% says it all

    • I think I’m confused by this comment. Apple has over 6,000 employees there and is currently the largest corporate tax payer in the Ireland. Are you trying to argue that Apple should be taxed in every country based on it’s global income? Meaning that if Apple sells me a phone in the states that profit should be taxed here, there and in every country Apple does business in on the face of the earth?

      Currently (and this is obviously simplified) The money Apple makes overseas is taxed overseas and the money Apple makes here is taxed here. We just went through this a few years back where our government wanted to tax Apple for all the money they made everywhere else in the world and force apple to bring it all to the states. The problem with both of these approaches is that it results in double taxation (for every country that does this). Is the goal for Apple to be taxed on the money it brings into that countries economy or to take as much as anyone and everyone can from people who are successful?

      Finally if Ireland insists that no deals were given and that they are happy with the arrangement, why try to stir up a problem when there has never existed one before?

      • Eurocratique

        “The money Apple makes overseas is taxed overseas and the money Apple makes here is taxed here. ”

        The thing is that they’re not being ‘overseas’ because they’ve got thiss separate separate ‘artificial’ company in Ireland with no employees etc where virtually all the sales from the EEA are processed and the profit is just dumped into that.

      • Here’s my whole problem with this. Apple technically did nothing Illegal. They paid 100% of the taxes that they were asked to pay, Ireland never once complained that they were being under taxed, and they were never denied or informed that their model of business would not be allowed.

        The EU Commission has now determined that Ireland cut them an illegal deal and is claiming that the country did so to promote jobs and push their economy. Which means that the government did something shady here. So rather than change the law to prevent this moving forward, and rather than hold Ireland’s government accountable; Apple is the one to get hit with billions of dollars in fines.

        But I find it interesting that Apple founded this company back in the early days before it was a major global force. Before they had thousands of employees and before they were worth billions. Funny how no one cared how Ireland was treating the underdog until that company became a global superpower. I just see a lot of hypocrisy and greed in this. If Apple did something intentionally wrong they should have to account for it. But in this case I don’t see this. Am I missing something?

      • Eurocratique

        the fine only covered the period of 10 years (and when apple was already very wealthy etc), which is when all tax claims can be contested etc. It’s part of company risk and they will have known that.

      • Sadly this goes beyond that. Again according to the laws of the land, Apple did nothing illegal. Perhaps a loophole or perhaps something that was never intended for a business as profitable as Apple, but again. Nothing illegal.

        To change the laws and then retroactively fine a company is a very dangerous precedent to follow. Especially since it ignores the actions of those that let it happen. It would almost be as if my government decided to outlaw guns and retroactively fined all its citizens for every year they owned their now illegal weapons.

        Should the law be changed or should the tax codes be re-written? Probably. Those are conversations for others with a lot more knowledge than I have on the subject. But this is corrupt and devious and altogether different.

      • Eurocratique

        The good news for apple is that any money they do pay back in back-taxes to Ireland can be deducted from their US tax ‘credits’ as they’ve already been taxed on it, so it won’t actually cost Apple much – just the US.

      • True, the bad news for Apple is just that they are being fined billions for the actions of a corrupt government. Nothing like being the scape goat for a cash grabbing political move.

      • Xee

        Are you totally naive !?

        The commission said the deal allowed Apple to pay a maximum tax rate of just 1%. In 2014, the tech firm paid tax at just 0.005%. The usual rate of corporation tax in Ireland is 12.5%.

        The commission said Ireland’s tax arrangements with Apple between 1991 and 2015 had allowed the US company to attribute sales to a “head office” that only existed on paper and could not have generated such profits.

        The result was that Apple avoided tax on almost all the profit generated from its multi-billion euro sales of iPhones and other products across the EU’s single market. It booked the profits in Ireland rather than the country in which the product was sold.

        Still think Apple are completely innocent? Give me a break!

        Apple will be paying up whether they like it or not. They will bring the lawyers out and it may take a few years and they may not pay the full amount (unfortunately), but in the meantime Apple have to put that owed money aside.

      • Please keep in mind that these numbers are for global revenue. That’s a bigger deal than most people realize. If every country Apple operates out of demanded 1% of Apple’s global revenue Apple would loose 97% of its profit immediately which would bankrupt them. When it comes to global income and tax rates the numbers aren’t going to look the same as for when you and I are doing taxes owed to our governments directly.

        Second it’s important to keep in mind that Ireland has never condemned Apple’s practices nor have they argued about them in any way. Not only that but if you look at the law of Ireland for taxes and corporation requirements you’ll find that neither one broke any laws. Were some loopholes used? Yup! But it’s something that’s known to everyone and everyone is ok with it.

        Enter the EU trade commission who is now suddenly claiming the ability to rewrite taxation laws for Ireland, turn this practice into a crime, and then fine Apple for violating a brand new law in retrospect. Apple did not violate Irish law.

        It’s a poor analogy but it’s the best I have off the top of my head. But imagine I’m a used car salesman, who is retired and simply enjoys tinkering with cars. I sell them for exact cost and don’t make a penny off of what I sell. I do what I do for the sheer love of doing it. However other used car lots are noticing that my hobby is cutting into their profit margins and band together to change city legislation that forces me to change my business practices to give them a fighting chance. But not only that, they then sue me for business damages to recoup their lost revenue due to my severely undercutting their sales.

        Now is it an exact match? no. However it does make the point. Until the changing of the law I was doing nothing wrong. Once the law changed I would be forced to update my practices. But is it right, for them to sue me in retrospect? And was I doing anything wrong by selling my hobby at cost? I think the answer to both of these is no. Just as it is in this case.

        I think taxes are a very personal subject for most of us and we enter these discussions with a fair amount of prejudice against large businesses with lots of money. But when looking at the law. I see nothing that Apple did wrong. If the EU is able to wrest sovereignty over taxation laws from Ireland and force them to change their tax codes that’s another thing altogether. Continuing in this arrangement would be illegal at that time and Apple would be guilty of illegal activities. However it hasn’t happen yet.

      • Xee

        Your analogies don’t make any sense to the matter at hand.

        Apple’s success in Europe has been partly as a result of a tax scheme deployed with the encouragement of the Irish authorities, which saw almost all profits generated by Apple sales in Europe funnelled through two Dublin-based entities, Apple Sales International and Apple Operations Europe.

        Apple may not be breaking the law due to the ‘sweetheart deals’ made with the Irish government. But Apple is seeking preferential treatment went it comes to taxation and getting it since 1991. Not only are they not paying taxes in all the EU countries they are operating in but are paying next to nothing in Ireland. This morally and socially wrong and proves that tax laws are broken and reform is needed.

      • Hey I totally agree with you that the analogy isn’t 100% accurate and I also agree that neither Apple nor anyone else should be able to operate in this manner.

        But like someone may point out in my analogy. We have families to feed and bills to pay. This guy who is just living off his social security and doesn’t have a care in the world is bankrupting our businesses. Just because he doesn’t have the expenses we do shouldn’t give him the right to ruin the businesses and lives of the other business men in our town.

        Now maybe both Apple and the Irish government are lying, but both have testified that there was no deal. That Apple never once asked for a deal, and everything done for Apple is freely available to be done for any other company. Now at the current time we don’t have any reason to suspect they are lying (innocent until proven guilty right?). This means that Ireland is pressuring the neighboring countries with very low tax rates and the other countries can’t compete with it. Because Ireland is willing to “work for free” and it’s hurting the businesses of the other countries they are banding together to shut them down. But again, wether or not we like it or not or it should be allowed or not. Is a totally different discussion. The question is, did they break the law? any law? Currently the answer is no.

        The more troubling aspect is that the EU is trying to wrest control of taxation laws from another country (never before done in history) and to then retroactively fine people based on a new law (also never before done in history). Both of these actions set what I believe to be a very dangerous precedent.

      • Xee

        Yes, but in their arrangements with Apple the Irish have not been complying with EU rules. That’s not to say Apple are innocent far from it. Ignorance is (as they say) no defence in the eyes of the law.
        The Irish government are more than happy with Apple’s tax arrangements, and that’s also part of the problem.

        There is nothing retrospective. The rules were there all the time and the tax files apparently are still open. The difference is just that the rules are finally being enforced.

      • Unfortunately it’s not quite that simple. Here in the US for example states are allowed to set their own tax rates. Several states have a 0% tax rate for corporations because this brings businesses to their states, increases local economies and the state still gets taxes off of the paychecks of the employees. Win-win for all right? Well not for the rest of the states that charge a lot of corporate taxes and don’t want to be competitive by cutting them back.

        Delaware (to pick a state a random) isn’t doing anything wrong by offering companies 0% tax rates according to the law. It is up to each state’s sovereign rights to do just that anyways. But if the neighboring states banded together to force Delaware to change its tax code and then fined companies to pay back taxes that would be the rough equivalent.

        I’d challenge you to show me the exact law(s) you say that the Irish government is breaking. Because up until 2 years ago the EU didn’t even look at taxation in terms of fair business competition. This is all very new and isn’t based on any real laws (yet). Furthermore if Ireland really is breaking the law, doesn’t it make more sense to prosecute Ireland instead of Apple? The very reason that Apple is the one under the gun for this I think reveals a cash grabbing agenda here motivated by greed. If this was really in the interest of fair play they would change the law, prosecute Ireland (if anything really turns out to be illegal) and move on with lives.

      • Xee

        Not sure what US states have anything to do with this. But having a 0% tax rate is not a win-win, you end up with parasite scum corporations – living off our roads – education – infrastructure – society – but demanding not to contribute through tax contributions!

        While over in Ireland, the Irish taxpayer was paying to subsidise the workers and their families through roads healthcare education etc etc. Apple was probably only actually putting in 200 million euros (a small meager amount) into the Irish economy every year – that barely covered the tax needed to provide the states provision to their workers while pushing up prices for others. And that’s just the financial ‘cost’ let alone the message it sends to others.

        The EU rules have been there all along. As I said before – There is nothing retrospective. The rules were there all the time and the tax files apparently are still open. The difference is just that the rules are finally being enforced. But I agree the tax laws do need to be changed to make tax avoidance a crime.

        Times are changing for big corporations, and time is running out when they can negotiate the fine lines between tax avoidance and tax evasion. To many people it’s the equivalent of committing a crime and getting away with it on a legal technicality.

        Anyway time to sit back with some popcorn and see how this all (eventually) unfolds.

      • The US has nothing to do with it. It’s just another similar situation. But yes it will be interesting to see how this all pans out as it could be the first time in history that a company is forced to pay taxes that the government insists they don’t owe.

        Again, I’d love to know which specific law was broken. I keep hearing about this in a nebulous sense but I haven’t had anyone able to point out which specific law(s) are in play that were broken.

        Sadly I agree with that assessment. A lot of people have a bias against rich people which I find disturbing. It’s funny how someone hears that Apple saved millions in taxes and shouts scandal! But then hears that Apple donates millions to charity and are quiet. None of us seem to want to compare the dollar value of the donations of the mega rich to our own. If we do we break it down into percentages and try to look at the picture relativistically. Strange how in taxes we don’t do that. Who of us wouldn’t take a tax break if it was legal and available? Apple is made up of humans just like us. If it’s legal why hate Apple for doing what we would do on our own smaller scale?

        My entire point in all of this has never been that Apple should have been allowed to do this. But that the EU is appearing to only be interested in cash grabbing politics at the moment in this endeavor and I think it’s sad that government agencies involved are being left out of the scandal and instead already talking about how to divide the profits should Apple take the fall for following the law. There is corruption here. I just think the bigger corruption is on the side of the government in this particular case.

      • Storm

        “Ignorance is (as they say) no defence in the eyes of the law.”

        This saying (from the Latin “Ignorantia juris non excusat”) means that you cannot plead ignorance as an excuse for breaking a law. But Apple haven’t broken any laws, so how does this apply here?

    • Xee

      Totally agree with you.

      Apple and the Irish Government know what they are up to and are both guilty. It’s not just Apple, it’s Google and others etc, they all have a social responsibility to pay the correct tax in each country that they do business in.
      When I buy an iPhone and have to pay tax/vat on that purchase, I expect Apple to pay that tax to my government. Not to be syphoning it through Ireland and paying 0.005% tax over there!

      As for the US government not being happy about the decision – they can go jump and mind there own business.

      The average person is sick and tired of these companies/wealthy not paying their fair share of tax (legal or not), this is part of that backlash and is well overdue.

  • Bill

    TAXES=THEFT. There is no valid argument against that. Plain and simple.

    • 9to5Slavery

      Especially from the corrupt government

    • jOn Garrett

      Taxes is theft? So WTF and HTF does government function without revenue?

      Do you want to pay per mile to drive on public roads?

      Pay private corporations for clean water?

      Would you like to fund a private Army or have none at all?

    • Can you explain to me then how things such as an organized army to protect your home, family and freedom is to be funded? Donations? Or how about things like upkeep of our transportation system? Fire Departments? Do you drive or ride with someone who does? Who pays for the things that we all enjoy nearly every day of our lives?

      Taxes are a very reasonable idea my friend. However when a government starts to get too big and starts wasting the money, putting the country in debt or taxing exorbitant amounts for unnecessary things that’s a different discussion altogether (and one I’d probably agree with you on). But at it’s simplest form, taxes are really an essential part of keeping a country running smoothly.

      Just something to think about,

      • jOn Garrett

        The problem isn’t government waste, the problem is citizens and corporations stealing.

        Take the situation here in NYC for example. Property owners don’t pay taxes on rental income, tenents pay billions in cash every year and almost none of it taxed. Businesses too, they don’t report all their cash income, some report none at all.

        So what does Govt do? Raise taxes or cut services. Who yells Govt waste? The biggest thieves and tax cheats.

        I’ll tell you a true story, before we had children, my wife and I were renters, we paid almost $70,000 in CASH over a 5 year period. Not one dollar of that money was counted by the property owner as income. We were just 1 apt in a 12 apt building so times that 11 more times, that is the minimum he made. Almost $1 million untaxed dollars. Multiply that by the 2 million apts in NYC and to that a million or so cash businesses.

        NYC losses billions a year in unpaid taxes.

      • While I believe firmly that (at least in the US) reckless government spending and wasted income is a very real issue. Our national debt is around $18,000,000,000,000 and yet we spend billions on things like teaching mountain lions to walk on treadmills, building cellphone games, and trying to find out if mother’s love dogs more than their kids. There are things that are essential to running a government. And then there are things that are not. And when we are in debt as far as we are I’m just saying that perhaps we should be a bit more cautious when it comes to spending and funding. So yeah, not everyone who complains about government spending is a tax avoiding scum bag 🙂 Haha, or at least, that’s not how I view myself 😛

        But yes, I totally agree that tax avoidance is a real issue that hurts everyone. I think you raise a great point and something needs to be done to reform our system so that people can’t get away with this anymore. However on the flip side, I also think there needs to be a distinction made between people that illegally avoid taxes and people that legally avoid taxes. If a law needs to be changed than it should be changed. But I don’t think it’s right or fair to hold someone morally culpable for something 100% legal.

        If Apple or the Irish government did something illegal they need to be held accountable and punished. If they didn’t then there isn’t anything to see here. The laws need to change and people need to move on.

        Personally I find the trend to view the rich are always guilty until proven innocent to be disturbing. Stereotyping and profiling a group of people just because they are wealthy is a sad state of affairs I think.

    • Xee

      It’s theft not to pay your taxes as well.

      • Bill

        Oh really? I’m stealing if I refuse to hand over MY money to the mafia who are demanding I pay them? You are out of your mind, along with the others claiming we won’t have roads unless someone steals our money. Preposterous! Enjoy your fairytale brainwashed world, Xee.

  • Rob

    Surely the EU must know this is a fruitless fight. There’s something we don’t know at play here. They are robbing CVNT5 tho, I can’t wait til we (gb) break off from them

  • jOn Garrett

    His message should have been:

    “iDiots, I mean apple fans always brag about our profits…. Well, now you know why. It’s because our competition pays their fair share in taxes and we pay none–and call it profit.”

    • I think you’re overlooking something. Every company can set themselves up in a manner similar to what Apple did over there. That means that everyone is on a level playing field which kind of negates your statement there. Second of all, Apple is the single largest tax paying entity in the entire country. Which means that whatever the situation is, compared to the competition Apple is paying (at least comparably) their fair share.

      Finally the numbers being thrown around here are intentionally misleading as they compare the ultra low tax rates of Ireland to Apple’s global income. Here’s the problem with that. If all 97 countries Apple works out of taxed apple for 2% of their global income Apple would have to pay out 194% of their profits in taxes. And it doesn’t take an accountant to figure out that this would bankrupt anyone.

      This whole case is crooked, and perhaps something needs to be done. Maybe these types of company setups need to be outlawed, or taxes raised. But it needs to be the government that allowed it to happen and gave it its blessing for decades that is responsible. Not a law abiding company.


    • Rob

      Plus it isn’t just apple doing it, as is said in the article. The competition diverts taxes to their own benefit also. Companies will always find a way of paying as little tax as possible within the confines of the law, even if some solutions turn out to be a little questionable sometimes, it’s up to the governments imposing the tax laws to close off the loopholes.

  • Bob

    The ‘problem’ looks complicated but brought back to the base it’s nothing more than they (Ireland/EU) change the rules during the play! When Apple established itself in Ireland it was at the current conditions of the Irish taxes. So Apple paid their duties and moved on, grew and kept on paying their duties. However now after several years all of a sudden they (Ireland/EU) smelled money and there you go. Apple is sued. IMHO the only thing they (Ireland/EU) could do is to revaluate their tax-system and rates and communicate this to Apple that from a certain starting point in the (near) future Apple has to pay more taxes hence they will be raised. But not like it seems to be the case, all of a sudden adjust the previous taxes and make Apple pay for that. Just absurd!