Ireland Apple escrow fund recorded first annual gain in 2023
Cork Hollyhill Industrial Estate, Pic Campus, Apple Cummins Co Larry
The account containing the money that US tech giant Apple must pay Ireland in back tax gained €400m in value last year, according to a new report from the Comptroller and Auditor General.
The total value of the fund stood at €13.794bn at the end of 2023, while its net assets accounting for outstanding liabilities totalled €13.774bn
It was the escrow account's first annual gain since its establishment in 2018 and followed five consecutive years of losses.
However, last year's increase in funds was driven by a higher interest rate environment, with the increased income and cash flows mainly due to holding and reinvesting in assets at higher yields, the report said.
Apple transferred €14.3bn into the escrow account in 2018.
The report said that 45% of the fund was invested in financial assets, while 55% was held in cash and cash equivalents, representing a significant change from the end of 2022, when 82% of the total assets were invested in financial assets while 18% in cash and cash equivalents.
The increased investment in short-term securities was in anticipation of the Court of Justice’s final judgement on the case, the report added.
Earlier this month, the ECJ delivered its final verdict on the long-standing Apple tax case, ruling against the tech giant in its latest legal bid against the €13bn tax order the European Commission said it must pay to Ireland.
In August 2016, the Commission issued its decision concluding that Ireland had given illegal State aid to Apple, ordering the iPhone maker to pay back €13.1bn plus interest of €1.2bn.
The escrow fund incurred operating costs of €6 million in 2023, unchanged from 2022, which primarily related to investment managers’ fees and escrow agent/custodian fees.
As of September 10 2024, the value of the escrow fund was €14.1bn following continued gains throughout the year, down €200m on the initial amount transferred by Apple in 2018.