"Apple had two entities incorporated but not tax resident in Ireland - Apple Sales International and Apple Operations Europe. These companies held the rights to use Apple's intellectual property under a 'cost-sharing' agreement with Apple Inc."
"Ireland agreed that the two firms were required to make annual payments to Apple towards R&D, meaning that enormous amounts of cash flowed to head offices of companies that existed only on paper."
"To put some perspective around this, Apple Sales International recorded profits of $22 billion in 2011, but under tax arrangements only €50 million was subject to tax."
"The arrangement resulted in the vast majority of Apple's European profits being effectively untaxed, or as Apple puts it, being taxed in the wrong jurisdiction."
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