This is the final decision in an eight-year legal battle over two Apple-owned companies, Apple Sales International and Apple Operations International, and their tax liabilities in Ireland.

In a conclusive decision which ruled out any option for further appeal, the ECJ ruled: ‘According to the Court of Justice, the General Court erred when it ruled that the Commission had not proved sufficiently that the intellectual property licences held by ASI [Apple Sales International] and AOE [Apple Operations International] and related profits, generated by sales of Apple products outside the United States, should have been allocated, for tax purposes, to the Irish branches.

‘In particular, the General Court erred when it ruled that the Commission’s primary line of reasoning was based on erroneous assessments of normal taxation under the Irish tax law applicable in the case, and when it upheld the complaints raised by Ireland and by ASI and AOE regarding the Commission’s factual assessments of the activities of the Irish branches of ASI and AOE and of activities outside those branches.’

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