BBC: Apple ‘to pay €318m’ to settle Italy tax fraud case. Several thoughts inevitably follow.
First, if the Italians have succeeded why haven’t HMRC even tried?
Second, what use is the General Anti-Abuse Rule if it could not be used against such abuse (so far it has not been used at all)?
Third, why the Diverted Profits Tax if cases could be brought in any event?
Fourth, have HMRC now asked for full details so they can replicate the case?
Fifth, when will we clear out the business heavy top echelons of HMRC so that an appetite for such cases is created in this country?