After an investigation which lasted for more than two years, Apple was given a substantial fine of €13 billion (US$14.5 billion) in August by the European Commission (EC) over its tax arrangements in the Republic of Ireland. Not only was Apple displeased with the EC's determination, the Irish government also expressed its dissatisfaction with the outcome and its intention to appeal the decision.
Nearly four months after the original verdict, Apple formally submitted its appeal earlier today. The premise of the company's appeal is built upon the notion that the EC ignored the assessments made by Irish tax experts, with Apple General Counsel Bruce Sewell commenting:
"The Irish put in an expert opinion from an incredibly well-respected Irish tax lawyer. The Commission not only didn't attack that - didn't argue with it, as far as we know - they probably didn't even read it. Because there is no reference (in the EU decision) whatsoever."
Apple also signaled its intention to challenge the basis upon which its penalty was calculated, citing that the "crazy notion of non-residency" was given deliberate preference over other tax regulations which would have otherwise returned a lower amount.
Ireland also took the opportunity to reiterate its position in support of the embattled tech company, while rebutting Commissioner Vestager's claim that the republic had specifically given tax benefits to Apple, saying that:
"Ireland did not give favourable tax treatment to Apple - the full amount of tax was paid in this case and no State aid was provided. Ireland does not do deals with taxpayers."
While the wheels continue to turn slowly, it seems all but certain that this case will be fought to the bitter end by all parties.