It is reported that at 1 a.m. on September 13, Beijing time, Apple’s 2017 autumn new product launch conference was held grandly at the Steve Jobs Theater in Apple Park. The most important one was the release of a new generation of iPhone. Now the attention of all fans and media around the world is here. Today, Finance and Taxation Master also takes this opportunity to tell you what companies Apple has and the purpose of registering so many companies.
"Apple US Headquarters" company
Registration place: United States
Headquarters: United States
Products produced: technology development, intellectual property< /p>
"Apple Patented Technology" Company
Registered Place: Bermuda
Headquarters: United States
Product Production: Actual Management and Operation
Purpose: Transfer U.S. assets. Companies registered in Bermuda do not need to declare taxes or pay any taxes, and there are no double tax treaties with other countries or regions.
“Apple OEM” companies
Companies responsible for apple processing: Samsung, Foxconn, etc.
Products produced: Apple mobile phones, MAC and other equipment
Reason: There is no need to build a factory yourself, the manufacturer has supporting equipment and a large number of cheap labor, and the cost is low;
"Apple International Sales" company
Registered place: all over the world
Sales products: Apple mobile phones, MAC and other equipment
Purpose: from "OEM" at low prices After getting Apple products, they resold them all over the world at high prices and received all sales revenue except the United States.
"Apple International Operations" Company
Registration place: Ireland
Headquarters: BVI (British Virgin Islands)
Operating products: Intellectual Property
Irish tax law stipulates that even a company registered in Ireland is considered a foreign company as long as its parent company (control) or headquarters (management) is located abroad. Foreign companies do not need to pay taxes to Ireland, so Apple aggregates income from Irish companies to its headquarters and does not need to pay taxes.
"Apple European Operations" Company
Registration place: Netherlands
Purpose: to transfer funds. Transferring sales income between Irish companies is subject to income tax, while companies in EU countries are exempt from income tax.
Dutch tax law stipulates that the company’s nationality is determined based on the company’s place of registration rather than the location of its headquarters.
The Netherlands and Ireland both belong to the European Union, and transactions between EU member states are exempt from income tax.
"Apple Global Services" Company
Registration place: Global
Purpose: to increase costs and reduce taxes
The cost of one unit is about 300 The US dollar Apple mobile phone is lying in the warehouse and has been "transferred" by several companies. The price can reach US$1,000. The reason is that it is a very valuable thing-intellectual property. Therefore, when we buy Apple devices, we are also using Apple's intellectual property.
So why does Apple register so many companies?
Let’s first take a look at the reversal of funds:
Irish Company A owns a large number of patents and intellectual property rights related to Apple products, and Irish Company B must use them when selling Apple devices. A large amount of intellectual property assets, so Company B needs to pay patent fees to Company A. If two Irish companies transfer directly, they need to pay a certain tax rate, but the transfer through a Dutch company does not. Therefore, the sales revenue is transferred to Irish Company A in the name of royalties, and finally transferred to the BVI Islands.
Service fees are deductible from service costs, intellectual property fees and fund transfers between EU companies are not taxable.
U.S. law allows an overseas subsidiary of a U.S. company to retain income derived from non-U.S. intangible assets. It does not need to pay taxes until the overseas subsidiary transfers the profits back to the United States. Therefore, as long as the overseas subsidiary does not transfer profits back to the United States, it does not need to pay taxes.
Now we know that Apple’s purpose of registering so many companies is actually to avoid taxes.
Since a company with a market value of 700 billion needs to go around such a large circle to avoid taxes, can Chinese companies do it? I don’t have such a large business and I don’t have international trade business. How should I avoid taxes? How can local Chinese companies learn from Apple’s tax-saving methods?
The answer lies in Horgos, Xinjiang, China.
Horgos is a red-headed document issued by the State Council, and the policy will not change until 2020.
Under the strong tax supervision of the third phase of the Golden Tax, no company needs to take risks and purchase invoices to avoid taxes. Reasonable tax savings can be achieved by enjoying tax policies through tax planning.