New documents show Apple went shopping for a tax haven after its famed "double Irish" tax avoidance scheme was threatened.
The world's largest technology company, which faces allegations it has avoided billions of dollars in tax, was among the targets of a 2013 crackdown on international firms exploiting Irish tax loopholes.
The Paradise Papers — the largest leak of documents in history — shows that Apple went to the law firm at the heart of the leak, Appleby, to help look for its next low-tax jurisdiction.
An email that is effectively Apple's shopping list for a new tax haven is among the 13.4 million documents examined by Four Corners and the International Consortium of Investigative Journalists (ICIJ).
The March 2014 email, among the trove originally obtained by German newspaper Suddeutsche Zeitung, shows Apple's law firm, Baker McKenzie, sent out a 14-point questionnaire to Appleby's offices in the tax havens of the Cayman Islands, the British Virgin Islands, Bermuda, the Isle of Man, Guernsey and Jersey.
Key among the questions was: "Confirm that an Irish company can conduct management activities … without being subject to taxation in your jurisdiction."
Apple also asked for assurances that the local political climate would remain friendly: "Are there any developments suggesting that the law may change in an unfavourable way in the foreseeable future?"
Apple went on to decide on Jersey, a tax haven that has a zero per cent tax rate, which was to play a significant role in Apple's newly configured Irish tax structure set up in late 2014.
Apple also went on to use the services provided by Appleby and its spin-off Estera in Jersey, 30 kilometres off the coast of northern France.
Under the new arrangements, the MacBook and iPhone-maker has continued to enjoy ultra-low tax rates on most of its profits and now holds much of its non-US earnings in a $252 billion mountain of cash offshore.
The Irish Government's crackdown on such tactics, meanwhile, has had little effect.
Apple's access to low foreign tax rates
Apple has led the field among multinationals exploiting offshore tax loopholes.
Despite almost all design and development of its products taking place in the US, Apple has been able to report that about two-thirds of its worldwide profits were made in other countries, where it has used loopholes to access ultra-low foreign tax rates.
Apple is being pursued for $US14.5 billion in Irish back taxes after European regulators ruled that Ireland had granted illegal state aid by approving Apple's tax structure.
Apple's efforts at tax minimisation appear to contradict Apple chief executive Tim Cook's 2013 evidence to a US Senate committee investigating Apple's tax minimisation.
"We pay all the taxes we owe, every single dollar. We do not depend on tax gimmicks … we do not stash money on some Caribbean island," he said.
In a statement to the ICIJ Apple said that, following its reorganisation, it pays more Irish tax than before.
"The changes we made did not reduce our tax payments in any country," Apple said in a statement.
"In fact, our payments to Ireland increased significantly and over three years [2014, 2015 and 2016] we've paid $1.5 billion in tax there — 7 per cent of all corporate income taxes paid in that country."
But the iPhone-maker will not say how much profit it makes through its Irish companies — making it impossible to gauge whether $1.5 billion is a lot of tax to pay in three years or not.
In Australia, Apple appeared before an Australian Senate economics committee in August where it revealed it had just completed a five-year audit by the Australian Tax Office.
Apple gave evidence that in 2016 it had paid an extra $58 million in tax for prior-year underpayments ahead of the conclusion of the audit.
The managing director of Apple in Australia, Tony King, told the committee that in 2016, Apple in Australia recorded revenues of about $7.5 billion, profit of about $400 million and tax of about $120 million.
