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Re:A Tax Expert Takes Tim Cook's EU Letter Apart Point by Point by pjc50 on Thursday September 01, 2016 @09:35AM (#12405096)
Effectively they argue that, in EU countries and India and Africa, the profit happens in Ireland. This is done through transfer pricing.

In Ireland, they argue that the profits happen at a "head office" which was not based in any country and did not have any employees or own premises.

(The ruling: http://ec.europa.eu/competition/state_aid/cases/253200/25320... linked from http://ec.europa.eu/competition/elojade/isef/case_details.cf...) - search for "AOI"

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