Summary by Futu AI
The European Court of Justice (ECJ) on September 10, 2024, overturned a previous ruling and confirmed the European Commission's 2016 State Aid Decision against Apple regarding tax arrangements in Ireland. The decision concerns tax opinions issued by Ireland in 1991 and 2007 about profit allocation of Apple's Irish subsidiaries from June 2003 through December 2014.As a result of this ruling, Apple expects to record a one-time income tax charge of up to approximately $10 billion in its fourth fiscal quarter ending September 28, 2024. This charge will significantly increase the company's effective tax rate for the quarter. The company notes that these figures are preliminary, and actual results may differ when final quarterly results are reported.The case's history includes Ireland's legislative changes in January 2015 that eliminated the application of the disputed tax opinions, and a July 2020 General Court decision that initially annulled the State Aid Decision, which was subsequently appealed by the Commission in September 2020.