Huge companies like Apple, Amazon, and Google have come under fire in recent months for their practice of keeping large portions of their profits overseas in countries that are more tax-friendly — Apple alone has a $100 billion overseas cash hoard that isn't subject to US taxes. As noted during Tim Cook's testimony to the US Senate this spring, the UK, and Ireland in particular, have been particularly tax-friendly to Apple. The Ireland-based Apple Operations International (AOI) is a holding company that pays no income taxes in the US and a very low tax rate in Ireland — but that's something that could change before long.
Ireland's Department of Finance just released a report (PDF) detailing the country's international tax strategy, and within it was a note about a potential change as part of Ireland's 2014 Finance Bill. The country says that it will consider a "change to our company residence rules aimed at eliminating mismatches — that can exist between tax treaty partners in certain circumstances — being used to allow companies to be ‘stateless' in terms of their place of tax residence." As noted by The Street, this potential change could remove the favorable tax status Apple currently enjoys.
Of course, we're a long way away from such a change going into effect — the Irish Independent says these rules won't apply until January 2015. And that's assuming that this proposal does indeed stay part of the 2014 Finance Bill. However, the company's finance minister says the country will be trying to be part of the solution to the overseas tax issues that have cropped up recently. "Let me be crystal clear. Ireland wants to be part of the solution to this global tax challenge, not part of the problem," Ireland Finance Minister Michael Noonan said.