If Apple has to pay-out - it's unlikely that Ireland will get anywhere near €13bn
The OECD's tax chief has said that most of the profits booked by Apple's Irish operations belong in the US.
When asked about the European Commission's ruling, Pascal Saint-Amans said that as the majority of Apple's research and development takes place across the Atlantic, that is where the profits belong:
"There is no ambiguity here: the bulk of it belongs to the United States," he said.
He spoke as he visited Dublin to meet with Finance Minister, Michael Noonan to discuss international taxes.
Mr Saint-Amans added that he was not surprised by the scale of the company's back-tax bill - but he doesn't believe that Ireland will see anything close to €13bn if the appeal against the EU ruling is unsuccessful.
"Maybe part of it belongs to Europe and part of what belongs to Europe belongs to Ireland," he continued.
He also commented on Ireland's 12.5% corporate tax rate, saying that it is not under threat:
"Clearly the US is much too high but I cannot say that Ireland is too low. It’s not. It’s accepted. Even the French have understood that Ireland will not change its tax rate. It’s here and it’s perfectly fine."
The process of reclaiming the €13bn (plus interest) that Apple owes following the European Commission's ruling which found that it had been given a sweetheart deal by the Irish government is going to be extremely messy.
While the Government and Apple have appealed against the decision - officials including Finance Minister, Michael Noonan, have repeatedly said that even if the ruling is upheld other European states may be entitled to part of the payout.
If the money goes to European states, this could lead to a shortfall in the US corporate tax take, as the company maybe able to avail of tax credits to reimburse taxes paid in other territories.