This allows tech companies to have their cake and eat it too by enjoying low tax rates on their entire European income without actually moving their operations to that country. If Google had 50,000 software engineers in Dublin, that would be one thing. But no one can seriously claim that any significant part of the work that produces Google Search goes on in Ireland, yet that is exactly what happens on their financial statements while they open a billion-dollar new engineering office in London.
Companies are free to move wherever they wish. They should not be free to claim they are domiciled somewhere that they plainly are not.
Hmm. Most of their European SREs who keep the service up and running are in Dublin, alongside most of their European customer support, European accountants, European legal team.
Arguably, they contribute quite a lot to the success of the service.
If they weren't there, would the service have made as much inroad compared to if they weren't.
So, arguably, their presence is _very_ material.
Also, you're missing the point of the single EU market.
Ultimately, it's a game of assignment and they chose to assign their sales(& IP?) to the country that was most attractive to them.
How would we tax a corporation as the number of employees trends to 0?
And if they have no activities in your country at all, what gives you a right to tax them?
>It's Apple claiming they should only pay Irish taxes on the profits of selling an iPhone developed in California, manufactured in China and sold in Italy because they have opened an office full of accountants in Ireland.
They're already paying various amounts of taxes in all of those regions. VAT is paid where the person buys the product, for example. Income taxes are paid where the workers are.