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Ahh right. And thus the 'Double Irish':

    It relies on the fact that Irish tax law does not include transfer
    pricing rules. Specifically, Ireland has territorial taxation, and 
    does not levy taxes on income booked in subsidiaries of Irish
    companies that are outside the state.
Funny - when it's phrased like this it seems a whole less clear about what Ireland (and Apple) has done wrong.

It's also worth noting that Ireland has passed tax reform to render this not possible any more.

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