Apple's 2019 results for its NZ operation reveal a dip in fortunes and, as in previous years, it's not clear if the tech giant paid any tax on this side of the ditch.
Apple Sales NZ's accounts for the year to September 30, 2019, show an 8.6 per cent dip in revenue to $838.2m.
After-tax profit dipped 22 per cent to $21.6m.
Salaries and bonuses payments reduced from $2.4m to $1.9m, indicating a possible reduction to the modest local team.
As with the local subsidiaries of most multinational tech companies, a dividend was paid to its parent: in this case $19.5m.
And Apple Sales NZ paid $8.3m in tax, or a total $9m before adjustments (which were primarily provisions for tidying up previous years' numbers).
That equates to Australia's corporate tax rate of 30 per cent, indicating Apple NZ's tax bill was ultimately paid to the Australia Tax Office (ATO) rather than the IRD in NZ, where the corporate rate is 28 per cent.
A tax partner at one of the big accounting firms told the Herald that because Apple's NZ operation is fully owned by the Sydney-based Apple Pty, it falls under a tax treaty between Australia and New Zealand designed to avoid double taxation.
A complex setup meant the ATO could demand Apple pay tax on its transtasman operation in Australia, because its New Zealand operation was managed from Sydney - but that Apple Sales NZ could also be liable to pay tax locally on profits generated here.
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One possibility was that Apple had paid a portion of its taxes to IRD, then claimed a credit on those payments then a "top-up" to the ATO to reach Australia's 30 per cent rate.
However, the tax partner added that with Apple's Company's Office filing offering no detail on the payments, it was impossible to comment where the tax payments went. A spokesman for Apple Australia told the Herald "Apple pays tax in every country we do business including New Zealand." He said that included both sales tax and profit tax.
Despite the possibility that NZ is missing out on tax revenue - something that appeared to rankle then-revenue minister Judith Collins when the Herald first raised Apple's Australian tax setup in 2017 - there is no suggestion that the setup breaks any law, and indeed it sees the tech giant paying a slightly higher rate of tax.
Where Apple pays its tax is rumoured to be an ongoing source of tension between IRD and the ATO.
A spokeswoman for the ATO declined to comment, saying the agency's transparency remit did extend to detailing tax paid on behalf of subsidiaries.
IRD has a long-standing policy of not commenting on individual clients, but has in recent times been on the front foot against Big Tech. Two multinationals, Microsoft and Oracle, have disclosed IRD investigations into profit and revenue shifting.
In its 2019 NZ result, filed last month, Microsoft - whose NZ subsidiary is incorporated in Bermuda - said it had reached a $24.7m back-tax settlement with IRD, covering June 2013 to June 2017. Oracle has yet to file its 2019 local result.
Australia pre-empted a slow-moving OECD-wide effort to clamp down on profit-shifting by introducing its so-called "Google tax". NZ's Cabinet is mulling its own possible unilateral move - a " digital services tax " that could be 3 per cent of revenue generated in NZ. But for now, the issue is parked on the back burner.
Google and Facebook have both sought to blunt possible legislative change by voluntarily changing their practices to pay tax locally on profit generated in NZ (previously, NZ bookings have been invoiced to subsidiaries in lower-tax Singapore or Ireland). Both are due to file their 2019 results, which should reveal the first impact of their policy shift.
Meanwhile, early indications are that Apple has enjoyed a strong start to the year. We won't know local numbers for another 12 months or so, but Apple's US parent reported record global results for its holiday quarter.