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Tax loophole for United States companies operating overseas just got tighter

17 September 2025

The unit has since paid the amount, the reports said.

After investigating the company, the Tokyo Regional Taxation Bureau found that the royalties earned from fees paid by Apple iTunes subscribers in Japan were withheld from the exchequer, with the money instead channeled through a licensing firm owned by Apple in the Republic of Ireland.

Treasury Assistant Secretary for Tax Policy Mark Mazur said the government was closing another tax loophole that contributes to the erosion of the USA tax base.

The extra tax was imposed on about 60 billion yen that iTunes transferred to Apple in Ireland over two years to 2014, the Yomiuri, public broadcaster NHK said and other media said.

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EU Competition Commissioner Margrethe Vestager called Apple's operations in Ireland a "sham", created to funnel revenue from across the globe to avoid paying tax. Recently, Apple had to pay 13 Billion Euros as a fine to Ireland for evading tax.

The new rule will prevent companies faced with back tax bills from "splitting", a strategy that allows companies to bring foreign tax credits into the United States without repatriating the income from which they were derived. Treasury issued the rule a year ago to prevent companies from enjoying a foreign tax credit when the related profits remained offshore. New rules on tax inversions, where companies move their headquarters to a lower-tax nation through mergers or acquisitions, also thwarted a proposed merger between USA drug giant Pfizer and Ireland-based Allergan. It alleged that the company had illegally received state aid.

Apple is one of many USA technology companies that have benefited from stashing cash overseas.

Acting shortly after a European Union grab for billions of dollars in back taxes from Apple, the U.S. Treasury said it was tightening restrictions on companies' use of foreign tax credits to reduce what they owe in U.S. taxes.

Tax loophole for United States companies operating overseas just got tighter