Technology giant Apple has been accused of adopting 'highly questionable' offshore tax avoidance schemes, which include the use of three Irish-based subsidiaries which appear to not be tax resident anywhere in the world.

The comments are contained in a report by the US Senate permanent subcommittee on investigations, which will be questioning Apple CEO Tim Cook on the company's complex tax arrangements later today.

The report says one subsidiary, Apple Operations International, which was incorporated in Ireland in 1980, has no employees and no offices anywhere, although it keeps bank accounts in the US. Despite reporting income of $30bn (£19.6bn) from 2009 to 2012, the company has not filed an income tax return in either the US or Ireland - or indeed anywhere else - for five years.

According to the committee, another Irish affiliate, Apple Sales International, reported sales income of $74bn (£48bn) over four years, but paid almost no tax. It reported pre-tax profits of $22bn (£14.4bn) in 2011 but paid just $10m (£6.5m) in tax, a rate of 0.05%.

Senator Carl Levin, a Democrat and chair of the subcommittee, said that Apple 'sought the Holy Grail of tax avoidance', by 'creating offshore entities holding tens of billions of dollars, while claiming to be tax resident nowhere'.

John McCain, the most senior Republican senator on the committee described Apple's approach as 'the epitome of tax creativity'.

Apple has released Tim Cook's statement to the committee before the meeting. In it he says the company 'does not use tax gimmicks'.

'Apple complies fully with both the laws and spirit of the laws. And Apple pays all its required taxes, both in this country and abroad,' Cook said.

Cook characterised Apple's relationship with the Irish subsidiaries as 'cost-sharing agreements', which were regularly audited by the US Internal Revenue Service, and said the subsidiaries shared risks as well as rewards. He called for an overhaul of US corporate tax laws so they are 'revenue neutral' for corporations.