A single row in a seven-page spreadsheet carries most of the story. Apple's public country-by-country report for fiscal 2025, filed under EU transparency law, records income tax paid on a cash basis of 17,081,182,976 dollars against its Ireland entry - 66.7% of the 25.6 billion dollars the company reports paying across every jurisdiction it operates in. The company attributes the size of that number to escrowed funds released to Ireland under the European Commission state aid decision.

The document arrived without a press release. Apple posted the file, titled Apple-Inc-EU-pCbCR-FY25.pdf, to the legal resources section of its website. It contains no publication date on its face; the embedded creation timestamp on the file reads August 19, 2026. Directive (EU) 2021/2101, which amended Directive 2013/34/EU and created the obligation, requires publication within twelve months of the balance sheet date. For a fiscal year that ended on September 27, 2025, that deadline falls on September 27, 2026.

The reporting period runs from September 29, 2024 to September 27, 2025. The reporting currency is US dollars. The subsidiary that published the report on behalf of a parent not governed by the law of a member state is Apple Operations International Limited, registered at Hollyhill Industrial Estate, Hollyhill, Cork. Apple ticked the option to report in accordance with taxation reporting instructions, which aligns the definitions used here with the confidential country-by-country reporting regime that tax authorities have received since 2016.

What the Ireland row contains

Twenty-two jurisdictions appear individually. Everything else is compressed into a single line marked as all other tax jurisdictions on an aggregated basis.

Ireland dominates every column except one. Revenues attributed to Irish-resident entities reach 213,562,634,548 dollars, or 43.6% of the 489,726,327,367 dollar total. Profit before income tax comes to 34,641,917,879 dollars, 36% of the group figure of 96,240,218,814 dollars. Accumulated earnings stand at 49,668,434,715 dollars.

Then the divergence. Income tax paid on a cash basis in the Ireland row is 17,081,182,976 dollars. Income tax accrued for the current year is 4,781,230,347 dollars. Measured against Irish-booked pre-tax profit, the cash figure works out at 49.3% and the accrual at 13.8%. The second number sits close to the 12.5% headline rate that has anchored Irish industrial policy for two decades. The first does not resemble a tax rate at all.

Apple explains the gap directly. Section 5 of the report states that income taxes paid to Ireland in fiscal 2025 were significantly higher than income taxes accrued, primarily because of the release of escrowed funds to Ireland pursuant to the European Commission state aid decision, with the corresponding tax expense booked in fiscal 2024. That is the accounting tail of a case that ran for eight years and ended when the Court of Justice of the European Union confirmed the recovery order in September 2024, overturning a 2020 General Court judgment and restoring the Commission's 2016 finding that tax rulings issued in 1991 and 2007 amounted to unlawful state aid worth roughly 13 billion euros.

A second explanation covers the rest of the world. Income taxes paid across all other jurisdictions also exceeded accruals, which the report attributes to instalments paid to the United States on the deemed repatriation tax imposed by the Tax Cuts and Jobs Act of 2017. That expense was accrued in fiscal 2018. Two settlements, both of them roughly a decade old in origin, are still moving cash in 2025.

The report treats none of this as anomalous. "Differences between income taxes paid and accrued are expected," it states, before setting out the mechanics: accruals capture the current-period charge on taxable profits, while payments can fold in instalments, final settlements, refunds for earlier periods and the outcome of audits.

The rest of the European map

Strip Ireland out and the picture changes shape entirely. The remaining twenty-one named jurisdictions and the aggregated remainder account for 276.2 billion dollars of revenue, 61.6 billion dollars of pre-tax profit and 8.5 billion dollars of cash tax.

Germany is the largest individually named European market after Ireland by revenue, at 2,721,812,306 dollars. Its pre-tax profit of 208,600,464 dollars represents a margin of 7.7%. Against that profit, the German row shows 152,138,606 dollars accrued and 153,468,036 dollars paid - accrual and cash rates of 72.9% and 73.6% respectively, roughly two and a half times the German statutory burden. Accumulated earnings in Germany are negative, at minus 523,854,784 dollars, the deepest deficit of any named jurisdiction.

France follows at 1,627,349,808 dollars of revenue and 166,320,613 dollars of profit, with 60,498,271 dollars accrued, an effective accrual rate of 36.4%. Spain records 1,093,563,345 dollars of revenue against 138,617,072 dollars of profit and a 26.5% accrual rate. Italy shows 1,066,930,411 dollars of revenue, 133,065,086 dollars of profit and a 32.5% accrual rate, with accumulated earnings of minus 46,895,676 dollars. The Netherlands, at 469,199,880 dollars of revenue, carries a 21.8% pre-tax margin, the highest of the large Western European entries.

Smaller markets produce results that do not look like distribution businesses at all. Poland reports 94,214,082 dollars of revenue and 90,680,998 dollars of profit, a margin of 96.2%, on a headcount of 56. Hungary shows 88.8%, Greece 84.1%, Portugal 83.1% and Norway 80.4%. Austria sits at the other extreme, with 221,798,374 dollars of revenue converting into 12,281,882 dollars of profit, a 5.5% margin, on 386 employees.

Cash and accrual also part company outside Ireland. Denmark accrued 9,538,661 dollars but paid 1,378,452 dollars, a cash rate of 4.1% against pre-tax profit. Austria paid 12,168,027 dollars against an accrual of 8,652,633 dollars, a cash rate of 99.1%. Türkiye accrued 65,354,590 dollars and paid 43,499,684 dollars.

Five named jurisdictions carry negative accumulated earnings: Germany, Italy, Czechia at minus 20,022,653 dollars, Sweden at minus 14,072,803 dollars and the Russian Federation at minus 171,958,400 dollars. The group total for accumulated earnings is itself negative, at minus 63,560,443,880 dollars, which means the aggregated remainder outside the named jurisdictions carries a deficit large enough to swamp Ireland's positive balance.

Four jurisdictions outside the European Union

The disaggregation requirement extends beyond EU member states to European Economic Area countries and to jurisdictions named on the EU lists of non-cooperative tax jurisdictions. Four non-EU entries appear.

Türkiye is the second-largest single revenue line in the entire report, at 5,458,826,470 dollars, ahead of Germany and behind only Ireland. Profit before tax is 401,705,236 dollars, a 7.4% margin, with 613 employees and accumulated earnings of 738,355,492 dollars. Viet Nam records 2,397,993,730 dollars of revenue against 63,281,526 dollars of profit, a margin of 2.6%, the thinnest in the report, across 207 employees. Norway shows 46,871,529 dollars of revenue.

The Russian Federation line is the outlier. Revenues of 3,599,771 dollars sit below profit before tax of 11,523,534 dollars. Income tax paid is negative, at minus 1,019,277 dollars, indicating a refund. Income tax accrued is zero. Accumulated earnings are minus 171,958,400 dollars. The employee count is one. The activity description for Limited Liability Company Apple Rus is listed simply as other.

The German deficit that is not a loss

Germany did not lose money in fiscal 2025. The German row shows profit before income tax of 208,600,464 dollars, income tax accrued of 152,138,606 dollars and income tax paid of 153,468,036 dollars. A loss-making operation does not accrue nine figures of corporate tax.

The negative number sits in a different column. Accumulated earnings of minus 523,854,784 dollars is a stock measure, not a result for the year. It records the cumulative balance retained inside the entities resident in a jurisdiction at the reporting date, after everything that has ever been distributed out of them. Under the taxation reporting instructions Apple elected to follow, the figure captures total accumulated earnings at year end, which means dividends and other distributions to shareholders reduce it just as trading losses do. The two causes are indistinguishable from the outside.

The group total settles the question of which cause dominates. Accumulated earnings across every jurisdiction in the report come to minus 63,560,443,880 dollars, against pre-tax profit of 96,240,218,814 dollars earned in the same twelve months. No company that profitable is carrying a cumulative deficit from trading. Apple's own consolidated statements point at the mechanism: the balance sheet published with its fiscal 2025 results shows an accumulated deficit of 14.264 billion dollars at September 27, 2025, narrowed from 19.154 billion dollars a year earlier, produced by 90.052 billion dollars of share repurchases and 15.413 billion dollars of declared dividends set against 112.010 billion dollars of net income. Retained earnings go negative when a company returns more to shareholders over time than it keeps.

The same arithmetic runs at subsidiary level: distributions from a German operating company to its parent reduce the German balance without touching German profitability, and the report captures the residue rather than the flow.

Entity structure compounds the effect. The German list in Section 3 names eleven entities, three of them partnerships: Apple Retail Germany B.V. & Co. KG, Apple Technology Engineering B.V. & Co. KG and Apple Technology Services B.V. & Co. KG. In such structures income is attributed to partners rather than accumulating at the partnership, and the general partners here are Dutch B.V. entities. Three further German entities carry the suffix i.L., the abbreviation for a company in liquidation. Wind-down balances and partnership attribution both push the aggregate down without indicating an unprofitable business.

A discrepancy is worth flagging. The minus 63.6 billion dollar group figure in this report does not reconcile to the minus 14.3 billion dollar accumulated deficit on the consolidated balance sheet, and the report does not explain the difference. The stated methodology offers the likely reason: entity-level data here is aggregated without eliminating transactions between related entities, so intra-group positions are counted repeatedly, in the same way that the 489.7 billion dollar revenue total exceeds the 416.16 billion dollars of net sales in the Form 10-K.

One German figure remains genuinely unexplained by any of this. An accrual of 152,138,606 dollars against 208,600,464 dollars of profit is a rate of 72.9%, roughly two and a half times the combined German corporate and trade tax burden. The report's note that profit is presented by jurisdiction of residence while tax is reported in the jurisdiction of the liable entity accounts for gaps of this kind in principle. It does not quantify this one, and the filing provides no entity-level breakdown that would allow anyone outside the company to close the gap.

The Russian Federation row is the only entry where a deficit does look like retreat rather than distribution.

Headcount, and where it sits

Summed across the twenty-two named jurisdictions, the report accounts for 18,417 employees. The aggregated remainder holds 147,261, for a total of 165,678.

Ireland carries 5,575, the largest named figure and a number consistent with Apple's long-standing Cork operation. Germany follows at 4,089, France at 2,611, Spain at 1,803 and Italy at 1,670. Below that the counts fall away sharply: Türkiye 613, the Netherlands 435, Austria 386, Sweden 379, Viet Nam 207, Belgium 166, Denmark 129, Czechia 119. Poland has 56, Finland 42, Norway 37, Hungary 27, Greece 23, Portugal 19, and Lithuania and Romania fifteen each.

Set the revenue figures against those counts and the structural point becomes visible without commentary. Türkiye books 5.46 billion dollars of revenue through 613 people. Ireland books 213.6 billion dollars through 5,575.

The entities behind the columns

Section 3 lists every consolidated subsidiary by jurisdiction, and it is the part of the filing that connects most directly to regulatory proceedings already on the record.

Eight Irish entities are named: Apple Data Services Ireland Limited, Apple Distribution International Limited, Apple Operations International Limited, Apple Operations Limited, Apple Retail Europe Limited, Apple Sales International Limited, Apple Sales Ireland Limited and IC Mask Design Limited. The activities span research and development, purchasing or procurement, manufacturing or production, sales, marketing or distribution, the holding of shares and equity instruments, and dormant status.

Apple Distribution International Limited recurs across the filing as a permanent establishment in Austria, Germany, Greece, Italy, Lithuania, the Netherlands, Romania, Spain, Sweden and Türkiye. That is the same entity named in European enforcement files. France's competition authority imposed a 150 million euro fine on Apple Distribution International Limited and Apple Inc. in March 2025 over the design of the App Tracking Transparency framework. Italy's competition authority fined the same entity alongside Apple Italia S.r.l. in December 2025, and named it again when it opened an iCloud interoperability investigation in June 2026. The corporate structure that appears here as a tax disclosure is the same structure that appears in competition dockets as a respondent.

The list also captures acquisitions. UAB "Pixelmator Team" appears under Lithuania. DATAKALAB, Blinksight S.A.S., Isotropix SAS and CCC Communication Holdings France appear under France. Limbak 4pi, S.L.U. sits under Spain, BIS Records AB under Sweden, and NanoScape GmbH under Germany. Several German entities carry the suffix i.L., the German abbreviation for a company in liquidation.

What the numbers do not measure

The report sets out four limits on how its figures can be read, and each one matters for anyone comparing them with Apple's Form 10-K.

Accrued taxes here cover current-year income taxes only. Reserves, prior-year adjustments and deferred taxes, all of which are required components of a US GAAP tax provision, are excluded, as are taxes accrued and paid on dividends from related entities.

Profit before tax is presented by the entity's jurisdiction of residence, while taxes paid and accrued are reported in the jurisdiction of the liable entity. The two do not have to match. Taxes levied by a parent jurisdiction on the earnings of foreign subsidiaries land in the parent's row, and withholding taxes land with the entity liable rather than the jurisdiction receiving the money. That single paragraph accounts for much of the apparent strangeness in the German and Austrian effective rates.

Entity-level data is "aggregated without eliminating transactions between related entities," which is why the 489.7 billion dollar revenue total in this filing exceeds the 416.16 billion dollars of net sales Apple reported in its fiscal 2025 Form 10-K. Intercompany flows are counted twice by design.

Section 4, reserved for omitted information, is blank.

Why an advertising audience has a stake in this

Apple's advertising business is small measured against its hardware, and large measured against its trajectory. eMarketer has estimated total Apple Ads revenue at roughly 8.5 billion dollars a year, a figure PPC Land cited when Apple reported services revenue of 30.7 billion dollars for the June 2026 quarter. Against 416 billion dollars of company revenue, that is a rounding error. Against the pace of expansion since the platform rebranded from Apple Search Ads in April 2025, it is a business being built out surface by surface, from additional App Store search placements to Maps advertising in the United States and Canada.

Advertisers buying those placements in Europe contract with Apple Distribution International Limited. So do developers. The Irish column in this report is where the money from those contracts is booked before anything else happens to it, which makes the filing a rare public view of the plumbing underneath a media buy.

The timing places the document inside a dense regulatory sequence. One day before the file's creation timestamp, Apple replaced the Core Technology Fee with a 5% commission on non-App Store sales and moved every EU developer onto a single set of business terms, a package the company framed as resolving its disagreements with the Commission. Six days before that, Germany's Bundeskartellamt issued a commitment decision giving Apple four months to redesign the tracking prompt. In July 2026, the General Court dismissed Apple's challenge to its gatekeeper designation under the Digital Markets Act. The Commission's 500 million euro anti-steering fine, imposed in April 2025, remains under appeal.

There is a fiscal thread running alongside the competition one. National digital services tax regimes already price advertising directly: rates run from 2% in the United Kingdom to 7.5% in Türkiye, and platforms including Amazon pass them through as regulatory advertising fees. Austria taxes online advertising specifically, France applies a 3% levy on targeted online advertising and data sales, and Washington State extended retail sales tax to advertising services in October 2025. Moving in the other direction, the Maryland Tax Court struck down that state's digital advertising tax on August 14, 2026 and ordered refunds to Google, Apple and Peacock.

The wider point is about disclosure rather than Apple. Fiscal 2025 is the first reporting year under the directive for most large multinationals with EU operations, and calendar-year groups face a publication deadline of December 31, 2026. Google, Meta, Amazon and the major holding companies will all file. Apple, with a September year-end, has arrived early. What its filing establishes is the format the rest of the industry will publish in, and the level of granularity - jurisdiction, revenue, profit, cash tax, accrual, accumulated earnings, headcount, entity list - that becomes routinely comparable across competitors for the first time.

Timeline

Summary

Who: Apple Inc., with the report published by Apple Operations International Limited of Hollyhill Industrial Estate, Cork, on behalf of a parent company not governed by the law of an EU member state. Twenty-two jurisdictions are itemised, and forty-plus named subsidiaries are listed, among them Apple Distribution International Limited, the entity that contracts with European developers and advertisers.

What: A public country-by-country report on income tax information covering fiscal 2025. Group revenue of 489,726,327,367 dollars, pre-tax profit of 96,240,218,814 dollars, income tax paid on a cash basis of 25,604,347,845 dollars, income tax accrued for the current year of 17,695,350,117 dollars, accumulated earnings of minus 63,560,443,880 dollars and 165,678 employees. Ireland accounts for 43.6% of revenue, 36% of pre-tax profit and 66.7% of cash tax paid.

When: The report covers the period from September 29, 2024 to September 27, 2025. The published file carries an embedded creation timestamp of August 19, 2026 and no stated publication date. The directive deadline for this fiscal year is September 27, 2026.

Where: Twenty-two individually named jurisdictions covering EU member states, European Economic Area members and jurisdictions on the EU lists of non-cooperative tax jurisdictions, with all remaining territories aggregated into one line. The report is hosted on Apple's legal resources pages.

Why: Directive (EU) 2021/2101, transposed into national law across member states, requires large multinationals with EU operations to disclose jurisdiction-level tax data publicly. Fiscal 2025 is the first reporting year for most groups in scope, which makes this filing an early template for the disclosures that Google, Meta, Amazon and the agency holding companies will publish through 2026. For advertising practitioners, it documents the corporate architecture through which European media spend and App Store commerce are contracted and booked.