Apple's Tax Planning Research

Founded in 1976,Apple Inc.is a high-tech company in the United States and has been publicly traded for more than 30 years.Specially,it is worth our attention that,shortly after its establishment,Apple Inc.quietly launched its strategic plan for tax planning of the entire company.Today,it has formed a complex and complete system.The US Senate launched a tax investigation around Apple in 2013.In the investigation report,it was mentioned that Apple's comprehensive calculation of the global burden tax rate was as low as 22%,and it was far lower than the U.S.federal's comprehensive tax rate of 35%.The reason for this is that Apple has used the tax system of the United States and other relevant countries in recent years,especially the loopholes in the taxation of overseas companies,and evaded the tax revenue of 44 billion U.S.dollars in overseas revenue(almost the same as annual 100 billion U.S.dollars).At the same time,the report also pointed out that Apple has about 140 billion US dollars of funds,of which 102 billion are overseas,and if the United States does not modify the relevant tax laws and tax rates,Apple did not intend to send these funds back to the United States.In recent years,Apple has issued 17 billion U.S.dollar corporate bonds to raise funds for launching related businesses in the United States.At the same time,it has used large amounts of overseas funds for shareholder dividends or investments in other businesses and has refused to bring overseas funds back to the United States.It also avoids or reduces the high tax burden on the United States tax authorities for paying taxes at high tax rates in the United States.None of the above-mentioned measures have violated the relevant laws.At most,they can only be categorized as some evasive tax avoidance actions against the spirit of the tax law.Therefore,in-depth study of Apple's tax planning strategy to understand the essence of the tax avoidance behind it has a profound practical significance for the improvement of China's tax system and corporate tax planning,especially the overseas corporate taxation strategy.This article combines Apple's organizational structure and business model to conduct case studies on the selection of taxpayer subject identities,cost sharing agreements,and transfer pricing tools.In addition,with the in-depth development of the globalization of the global economy,the internationalization strategy,that is,the production of companies,has become an important development plan for companies in the course of their operations.Countries,especially developing countries,have actively introduced foreign-funded enterprises by attracting foreign investment.The economic development of the country helps.Taking China as an example,China's foreign-invested enterprises implement a tax exemption policy of "two exemptions and three reductions".In addition,it also actively implements the "going out" strategy and encourages outstanding domestic companies to actively explore the international market.Therefore,the study of the tax planning of this multinational company,such as Apple,also has a positive reference for China's large multinational companies in the global tax planning.In addition,as a multinational operating entity of rational economic people,the enterprise will inevitably achieve the goal of maximizing profits.Under certain circumstances,the international taxation plan will be adopted to minimize the tax cost of the company and increase the number of companies as much as possible.Profit after tax.However,from the perspective of national taxation,the phenomenon of global tax avoidance by multinational corporations has become increasingly fierce.The use of multiple forms of profit transfer to reduce tax liability in the course of operations has caused erosion of the country's tax base,which has also attracted the attention of various countries.In international conferences,they proposed international issues for preventing and responding to tax base erosion and profit transfer.This article through the study of Apple's tax planning,introduced the evolution of the international tax system at the same time,the tax game between enterprises,countries,which also has great significance for the domestic tax reform,the development of the enterprise itself.