The European Union has a fight on its hands. Apple Inc. (AAPL) filed an appeal to challenge the organization’s tax ruling that directed the Irish government to collect approximately $13.6 billion in back taxes from the company. The company is not mincing words in its fight against the EU: the lead lawyer on the case told Reuters Apple was a “convenient target” for EU Commissioner Margrethe Vestager because she is “driven by headlines.” The U.S Treasury Department also jumped into the game, charging the commission with retroactively applying a “sweeping a new state aid theory.”  “(The theory) is contrary to well-established legal principles, calls into question the tax rules of individual countries, and threatens to undermine the overall business climate in Europe‎. Moreover, it threatens to erode America's corporate tax base," the department stated.  

Apple’s filing today follows a statement by the Irish finance ministry yesterday that claimed the EU had exceeded its powers by attempting to rewrite Ireland’s low tax rate regime. “Ireland does not accept the commission’s analysis, which is why we have lodged an application with the General Court of the European Union to annul the whole decision,” the finance ministry stated, adding that the Apple paid the full amount of tax and denying that state aid was provided to the company. (See also: Ireland To Appeal EU Decision On Apple Taxes). 

The EU’s case against Apple and other tech companies has become a flashpoint in trade relations between Brussels and Washington. Alphabet Inc. subsidiary Google (GOOG) and e-commerce behemoth Inc. (AMZN) are also caught in the EU’s cross hairs over favorable tax treatment. For all the sound and fury, however, the amount demanded by the EU in back taxes is a drop in the ocean for Apple, which had $200 billion in cash reserves parked abroad as of January this year. (See also: After Apple, EU Takes Aim At Amazon). 

Still, the EU’s case against Apple could set off similar demands elsewhere. President Obama’s administration has claimed that the ruling sets “disturbing international tax precedents.” In fact, the EU’s ruling has been followed by similar demands for tech companies from governments across the world, such as Indonesia and India.

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