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Value of €14 billion Apple tax fund fell €36 million last year as Ireland awaits decision on whether it should take the money


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THE €14 billion escrow fund, jointly owned by Apple and Ireland, fell by €36 million in value last year and will take years yet to resolve, the Dáil Public Accounts Committee has been told.

Ireland won a ruling at European level in 2020 that its tax deal with Apple had not broken competition rules, and therefore was not owing to the Exchequer here — as this country had argued.

However, the European Commission has appealed the case to the European Court of Justice, and a final ruling “could be another couple of years,” said Susan O’Halloran, chief financial officer of the National Treasury Management Agency (NTMA).

Conor O’Kelly, chief executive of the NTMA, said the escrow funds were invested at lowest risk, and in current conditions an annual decrease in its value as benchmarked at minus €70 million.

It was therefore “outperforming” expectations, which were for best “return of capital, not a return on capital.” The escrow is paying €7 million in administration fees, overseen by Bank of New York Mellon, which he said was “modest”.

European Competition Commissioner Margarethe Verstager initially made a determination that the Ireland-Apple arrangement had broken level playing pitch rules, and the monies should be paid to Ireland in tax, despite arising from sales in many other countries.

The Government, led by Finance Minister Paschal Donohoe, denied Ireland was entitled to the money and appealed the ruling, saying it was important to defend Ireland’s sovereign tax arrangements — which are expected to change today with agreement to sign up for a 15pc corporation tax rate.

The Irish Strategic Investment Fund (Isif) has meanwhile lost €3bn through its stakes in the main pillar banks. The State still owns 70pc of AIB and 14pc of Bank of Ireland following the financial collapse in 2009.

The current AIB valuation is €4.5bn and Bank of Ireland €600m, although both share prices have been sliding. The overall value of the Isif fell from €15bn in 2019 to €12.7bn last year.

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The NTMA also revealed that a total of €36bn had been borrowed to date to meet the pandemic challenges, with the complete emptying of the €1.5bn Rainy Day Fund.

It was to put a “floor under the economy”, Mr O’Kelly said, and the average interest rate was 0.16pc, while the European Central Bank (ECB) had begun buying sovereign bonds within seven days of the crisis, having taken seven years to engage in so-called “quantitative easing” in the wake of the financial crisis.

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