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To expect Apple to retroactively pay such a sum when they had a legal agreement with Ireland is absurd. I’m no Apple fan but this is Ireland’s problem, not Apple’s.

This is no different than saying, “We changed our minds about what taxes you should pay since 2003, now you owe us $13 billion”. Apple was following the stated law. The fact that it did not reconcile with EU laws is not Apple’s responsibility to resolve. It just goes to show what an unworkable legal environment the EU is with respect to its members and their law.

Moving forward, how is this not a toxic economic environment for business? The EU is supposed to be some great economic positive yet here they show that you can be retroactively punished even when you played by the rules. It just highlights the monster that is the EU, another unnecessary layer of bureaucracy that needs feeding. Unaccountable individuals using the system to enrich themselves. It is an abomination.

The thing is that Apple created two companies in Ireland -- one that does actual business (people, hiring, manufacturing, services etc) and the other called Apple Operations International -- the head of tax operations for Apple,Phillip Bullock, told a U.S. Senate committee in 2013 that “A.O.I. is incorporated in Ireland; thus, under U.S. law it is not tax resident in the U.S. A.O.I. is also not tax resident in Ireland because it does not meet the fact-specific residency requirements of Irish law.” It’s Irish, according to American law; not Irish, according to the Irish. A.O.I.

Ergo - it does not legally exist anywhere, but it holds the profits from Apple sales outside of the United States, holds until the US declares a tax holiday year (as it did in 2004 when repatriated amounts were taxed at 5% - that's when it brought back a lot of money)