back to article Tim Cook: EU lied about Apple taxes. Watch out Ireland, this is a coup!

Apple’s chief executive Tim Cook has claimed that the European Commission made up its claims about the business’ tax payments in Ireland. Earlier this week EU competition commissioner Margrethe Vestager said that Ireland failing to collect taxes from Apple at the standard rate of 12.5 per cent amounted to “state aid” and thus …

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  1. graeme leggett Silver badge

    On the radio this AM

    Listened to some of it as broadcast by Today.

    Cook comes across as much as a politician would, managing to project a sort of weariness at the folly of Apple's opponents and bullishness at being in the right and that the appeal will succeed.

    1. Dr Scrum Master
      Flame

      Re: On the radio this AM

      Just heard Tim Cock's interview re-broadcast on the World Service.

      It may take a while for my blood pressure to recover...

    2. Anonymous Coward
      Anonymous Coward

      Re: On the radio this AM

      Is the interview available online?

      1. graeme leggett Silver badge

        Re: On the radio this AM

        Today, which broadcast elements of the interview http://www.bbc.co.uk/programmes/b07qbfvr

        this I believe is the Irish station and programme original http://www.rte.ie/radio1/morning-ireland/

    3. Anonymous Coward
      Anonymous Coward

      Re: On the radio this AM

      Listen carefully to what he said, it was something along the lines of "we paid ... corporate income tax".

      Does he actually just mean employees income tax which, I assume, is sent to the treasury before the money is paid net to the employee? It would have been good for the interviewer to have been a bit harder on him and specifically asked how much corporation tax they paid that year to anywhere in Europe and how much revenue and gross profit they made in Europe. I think he would have stumbled on that one.

      The point is, there is no reason to have the company structure that they have if they were paying all the expected European taxes. The fact that Ireland allowed it amounts to not making them pay 12.5% on profits in Europe. That amounts to artificially helping a company - state aid. Similarly Ireland would not be allowed to charge them the full corporation tax rate but allow Apple to make special one off iPhones for the Irish government that they would purchase for 100 million Euros each.

      1. ragnar

        Re: On the radio this AM

        He probably didn't mean this. Corporate Income Tax, CIT, or "income tax" is often used around the world to refer to something similar to our corporation tax. It's more of an Americanism than a deliberate attempt to conflate employee taxes with corporation taxes. You are quite correct that this is a common theme though and needs to be stamped on.

        1. Anonymous Coward
          Anonymous Coward

          I don't think Cook is handling this correctly

          If I was his publicist, I would tell him he should say "Apple fully complies with all tax laws in every country in which we do business. As many companies do, we try to minimize the amount of taxes we owe under the law. We do not believe the EU is correct in their assertions, but this is up to Ireland and the EU to determine. If the final determination is that Apple owes back taxes because Ireland did not follow EU rules, we will pay the taxes we owe, though the EU should strongly consider whether retroactive changes to tax rates is the proper way to achieve their goals. While Apple is in a position to pay, other companies in a similar position could feel significant financial stress"

          And then refuse all further comment, referring to his previous statement that it is up to Ireland and the EU to determine.

    4. Anonymous Coward
      Anonymous Coward

      Re: On the radio this AM

      He is playing it like a politician. The empty promise to repatriate income so he can trying playing USA against Eu is just priceless.

      The Eu has built up decades of experience in fighting taxation derived state aid cases against member governments and local governments in member states. So far, on the current competition commissioner's watch, 40+ multinationals including Fiat, Starbucks, BP, etc have failed to challenge similar decisions so he can continue the bravado as much as he wants. It will not help against the knitting lady - she gives no quarter.

      I have zero sympathy for him in any case. As I have said before, money is like manure, you need to spread it around to make new things grow. In that respect, the state "inefficiency" is actually beneficial directly and indirectly when redistributing money obtained via taxation. The direct benefits are obvious: when money was mostly circulated in-country and taxed in the 60-es and 70-es we had significantly higher proportion of GDP dedicated to R&D in the developed world. We also achieved more as the state was subsidizing fundamental science instead of the current VC/Multinational driven money spend on yet another social bollocks sharing economy startup.

      The direct and obvious effect on R&D spend, however, pales by comparison to the indirect effect. When money is taken out of circulation in quantities comparable to countries' GDP (as it is now) and Leprechauned (as by Mr Jobs and Mr Cook), inflation drops forcing multiple levels of perversion of the market by regulators: quantitative easing, forced stimuli, etc. That in turn hurts all (but the super-rich) across the board. So, frankly, from a long term socio-economic perspective we should all keep our fingers crossed for the knitting lady to succeed here. Unless we want to live in a Elysium like dystopia of course.

  2. Mage Silver badge
    Devil

    Well, bears in the woods etc.

    Very predictable response that rings a little hollow.

    They may win the appeal on a technicality. However their greed is now clearly exposed. If Apple owes nothing in Ireland, that still leaves some issues:

    The flagship products in terms of design are largely only cosmetically and software Apple US origin.

    They use the same kinds of parts and same factories as products selling for a fraction and they have a four times bigger profit margin.

    They consistently try and flout EU SOGA on their direct sales.

    Their accounting and tax may be legal, but they are like a dragon sitting on all that cash. Taking cash out of the world economy is hurting it. They are parasites, though of a different less evil kind to Facebook and Google.

    They don't spend very much on real R&D, their incremental Software Development and their Patent Applications preparation and costs come out of that budget. Most of their innovations (Multitouch GUI from fingerworks) are bought in. Remove style and cosmetic and stupid things and what is left?

    Where do they pay any tax on their profits?

    Really they are a cosmetic badge operation of Asian and generic HW with USA gloss. So why does Silicon Valley, Obama etc rush to defend them? A tiny proportion of their profit is spent in USA.

    1. maffski

      Re: Well, bears in the woods etc.

      '..They use the same kinds of parts and same factories as products selling for a fraction and they have a four times bigger profit margin... ...generic HW with USA gloss...'

      And there you have it. It's everyday gear, so all that extra profit must lie in the IP (design, ecosystem, brand etc.). And that is based in the US, and taxed under US rules. So Ireland hasn't provided state aid and this ruling is either the start of a political land grab or, more likely, just for some big headlines.

      1. P. Lee

        Re: Well, bears in the woods etc.

        >so all that extra profit must lie in the IP (design, ecosystem, brand etc.). And that is based in the US, and taxed under US rules. So Ireland hasn't provided state aid

        I thought the opposite was true. Apple-Ireland holds the IP but the Irish government doesn't make Apple pay tax on sales outside Ireland.

        The question is whether Apple's arrangement was fair and comparable to any other corporate in the same position.

        1. Anonymous Coward
          Anonymous Coward

          Re: Well, bears in the woods etc.

          I thought the opposite was true. Apple-Ireland holds the IP but the Irish government doesn't make Apple pay tax on sales outside Ireland.

          Correct.

          The question is whether Apple's arrangement was fair and comparable to any other corporate in the same position.

          No. Two questions:

          1. Was it legal under existing Eu taxation treaties and harmonization directives? While tax was never fully harmonized, partial harmonization has been part of even the earliest Eu treaties. This includes all Eu members charging VAT (with any exception being negotiated), all Eu members charging corporate tax (no exception) as well as all members charging NI and income tax to allow benefits to be transferable.

          2. Was the failure of Ireland to comply with its commitments to Eu tax harmonization a form of state aid and was it deliberate and advertised to corporations in order for them to settle in Ireland. I suspect that there was at least one person in the Irish government to advertise it in the last 20 years which pretty much makes this an open and shut case outright.

      2. Anonymous Coward
        Anonymous Coward

        Re: Well, bears in the woods etc.

        Unfortunately for your argument, the basis for funnelling profits made outside the US through Ireland, and it's extremely generous tax treatment, is the notion that the Irish companies own the ex-US IP rights. The result is that Ireland makes a small but (for them) decent amount of tax, at the expense of every other country where those products were actually sold, and Apple pays stuff all by comparison with "normal" companies. Nice deal if you can get it.

      3. Aitor 1

        Re: Well, bears in the woods etc.

        Nope, it is not taxed in the US either.

        1. Major N

          Re: Well, bears in the woods etc.

          the way it works is Ireland won't tax the proportion of the value that is added by US Apple operation, Apple claim it is most of the value, due to the R&D, design, software manufacturing etc. taking place in the US, and thus it's taxable in the US, not Ireland. Ireland shrug and say 0.005% of a shitload of cash is better than none, and take the money, Apple ship the money to Bermuda and sit on it. Uncle Sam stares across the Caribbean, and waits.

          So, Technically, it will be taxed by the US... IF they ever 'repatriate' it to the US from the Bermudan Black Hole. This is why they sit on $Bns in a tax exile while not paying dividends etc, because the instant they try to spend it, the IRS will take their rather generous cut.

          1. Naselus

            Re: Well, bears in the woods etc.

            "So, Technically, it will be taxed by the US... IF they ever 'repatriate' it to the US from the Bermudan Black Hole."

            Which they will only do when they're offered a repatriation tax holiday. Which was why many people argued against Bush 2's 2004 holiday, because it would just encourage corporates to sit on offshore cash mountains and wait for another one.

            It's really amazing how many different ways George W Bush's presidency has managed to produce ongoing disasters.

      4. oldcoder

        Re: Well, bears in the woods etc.

        Ah, but as I understand it, US taxes do NOT include sales outside the US.

        Thus the profits you mention that would have been taxed in the US are not... making the profits even larger.

    2. StaudN
      Facepalm

      Re: Well, bears in the woods etc.

      I was right with you until you said "though of a different less evil kind to Facebook and Google".

      What scale exactly are you using for that sweeping statement?

    3. CaptTofu

      Re: Well, bears in the woods etc.

      "greed". So the company, which employs people, makes things of value that people want, is greedy, but the EU apparatchiks, who produce nothing but always want a cut of the profits ( but none of the losses), are not greedy. See exhibit B, collectivist mindset.

      1. Anonymous Coward
        Anonymous Coward

        Re: Well, bears in the woods etc.

        How much money Ireland got from EU to save its butts? Where do you believe those money came from? Taxes paid by other EU citizens.

        1. Slx

          Re: Well, bears in the woods etc.

          They were actually high interest LOANS not grant aid. Not a cent was written down. The bail out is a whole other kettle of corporate fish. The Irish were effectively forced to borrow vast amounts of money under the "no banker left behind" policy.

          Don't worry, other EU tax payers got or are getting that back, with hefty interest and avoided their banks going bang as a result.

      2. katgod

        Re: Well, bears in the woods etc.

        Agree CaptTofu,

        (bears in the woods) statement makes everyone who does not pay more taxes than they need to greedy.

        If one disagrees with a particular tax rate, then one should change that tax rate if they can get others to agree with their new improved rate.

    4. Anonymous Coward
      Anonymous Coward

      Re: Well, bears in the woods etc.

      Wow. This is a hollow a comment as you'll read about tech.You managed to say nothing imaginative or relevant in just over 200 words. I wrote a pithy and detailed response but before posting it, I realised that you really are not worth it. You are just another gobshite commenter talking about something that they clearly know nothing about. And it's really dull.

    5. Anonymous Coward
      Anonymous Coward

      Re: Well, bears in the woods etc.

      anon obviously - this tax dodge is worked everywhere.

      I worked for years for a UK company in the US - this company (currently listed on the UK stock market) arranged its accounts every year so that the sales made in the US were always unprofitable. Every year we had to send all our accounts to the UK at the start of December and each time, before the end of December, we would receive a management services invoice that nulled out our profits.

      I left the company many years ago - in part because I couldn't believe that they would keep on getting away with this and didn't want to have any part in it, and because running an unprofitable company means that you get paid very little and have no influence on corporate policy. It seems that they continue to make most of their profits in the US, I've no idea how they handle their accounting these days but the upper management hasn't changed so it's a safe bet their tax dodging hasn't changed either. Their stock price is doing nicely however.

    6. Schultz

      "Their accounting and tax may be legal"

      Or maybe not. The EU commission found that the Ireland headquarter was a fictitious entity, set up purely to avoid taxes. In many countries, it is illegal to do such a thing. Consider what might happen to you when you just make up stuff in your tax return declaration to avoid paying your share.

      I believe that Apple might be in quite some trouble once the national tax authorities in the rest of the world wake up. Good thing they got some money in the bank to get this sorted out :).

    7. Anonymous Coward
      Anonymous Coward

      @Mage wow, so many wrong statements in that trolling post

      "their greed is now clearly exposed" - Please list the large multinational companies that don't try to minimize the amount of taxes they owe/pay.

      "less evil kind to Google and Facebook" - From your first few paragraphs it sounds like you are practically equating Apple to Hitler's more evil twin, but Google and Facebook are worse? Care to share with us your evilness scores for various companies and historic/fictional figures like Hitler and Satan so we understand the degrees of evil you are able to divine?

      "They don't spend very much on real R&D" - Apple's R&D budget is over $10 billion. That BILLION with a 'B'. That's more than the revenue of most companies. Or is it somehow not "real R&D" to you if it is Apple doing it? If so, what do you consider real R&D, and which companies are doing it?

      "Most of their innovations are bought in" - that's true for most companies. You didn't think Microsoft invented DOS, Word or Excel, did you? I guess they invented Windows, but only after they'd had a look at the Mac once Apple had figured out how to take a GUI out of the lab (which they compensated Xerox for in terms of stock options, and saw with their permission) and work it into something ordinary people could use rather than the PhDs who used Xerox's Alto prototype. The only thing Google invented was search, they've bought in everything else from Android to Maps to their advertising network that actually makes all their money. And they didn't even invent search, they just invented the 'page rank' algorithm that made search better (well until SEOs found it was easy to game by creating link farms)

      "Where do they pay any tax on profits?" - they pay full whack on all their profits in the US, and are the largest single taxpayer in the US. More than Wall Street banks, oil companies, retailers like Walmart, and so on. US law doesn't require them to pay taxes on overseas profits until they bring the money home, and they haven't brought the money home. They arranged things overseas in an advantageous fashion for them to minimize the taxes they pay there, just as almost all large multinationals do. They make more money than any publicly traded company in the world, so they are an obvious target when tax authorities decide to start overturning couch cushions looking for more money.

      "Cosmetic badge operation" - yeah, they should make everything in the US like all these other US based consumer electronics companies do like Samsung er I mean Panasonic er I mean Lenovo er....oh wait US companies...I know Dell, nope guess again, IBM, nope guess again, Microsoft, nope guess again...

  3. FF22

    Just dumb

    Tim Cook is dumb or just playing dumb. Contrary to what he claims there's nothing new about the ruling, and the EU has already a tax control code in place, which Ireland - in cooperation with Apple, Google, and co - deliberately ignored. The ruling adds nothing new there, it merely confirms that the attempt to get around the code - that has been existing for multiple decades now - was illegal and futile.

    Cook is also wrong that Apple and Ireland would have the same interests. They do not. Ireland's interest are collecting all the back taxes from Apple - and the latter of course wants to avoid having to pay that.

    Apple can try to appeal the issue, but really, the only thing they can achieve is that they'll have to pay even more interests on back taxes. The rules are and were always clear. Apple definitely tried to break the EU tax code (in cooperation with Ireland), and now they got caught and will have to pay for it.

    1. Dan 55 Silver badge

      Re: Just dumb

      Ireland's interest isn't collecting back taxes, in fact they're appealing. They would get €13bn now and probably have to hold the door open while the multinationals leave in an orderly fashion later. They would prefer to carry on having a goose which lays golden eggs.

      1. lglethal Silver badge
        Stop

        Re: Just dumb

        Nonsense. Ireland will say its appealing, may even go through the motions, but in the end they will lose and turn around and say "aww im sorry, we tried so hard. Better luck next time. Can we please have the equivalent of 2 years worth of our government budget that the EU says you have to give us? Sorry we really don't want it, but you know what can you do. The EU aren't they bastards, eh? "

        It's always the EU's fault. Even when its not.

      2. Charlie Clark Silver badge

        Re: Just dumb

        They would get €13bn now and probably have to hold the door open while the multinationals leave in an orderly fashion later.

        Where else in the EU should the companies locate to?

        1. Dan 55 Silver badge

          Re: Just dumb

          Where else in the EU should the companies locate to?

          Luxembourg seems quite popular and for some reason Juncker doesn't kick up much of a fuss over their tax.

          1. Anonymous Coward
            Anonymous Coward

            Re: Just dumb

            Luxembourg-based companies like Amazon are the next in the list...

      3. sjiveson

        Re: Just dumb

        Apple and other companies should NOT be blackmailing nations with a choice between investment (including jobs) or paying tax. They, like most companies in the world, should be providing the first and paying the second. Anything else IS an unfair advantage.

        Where exactly will those investments and jobs go? Is another European country likely to offer a similar deal? If not, and they have no base in Europe I'd imagine they can't do business here. That's the choice they should and hopefully do now face.

        1. ecofeco Silver badge

          Re: Just dumb

          Apple and other companies should NOT be blackmailing nations with a choice between investment (including jobs) or paying tax.

          It isn't blackmail, it's extortion and I'm personally fed up with it as they would not get away with this if the politician weren't undeniably complicit and directly benefiting from it.

        2. Anonymous Coward
          Anonymous Coward

          @sjiveson - tax blackmail

          No, companies shouldn't blackmail governments over taxes but it happens all the time. Not just on an international level. In the US companies will move from one state to another, or choose the site of their factory, based on tax incentives they are offered. Sometimes the laws are written so that only that one single company can take advantage of them!

          It even happens at a local level. A department store based for at least 20-25 years at a mall located in the city where I live was induced to move about 5 miles to a suburb thanks to a property tax break of $1 million a year for 15 years. You'd think that wouldn't happen between cities that are "neighbors" but they wanted an anchor store for a new riverfront re-development they were doing and the fact it would leave a big hole in that mall that ended up taking almost five years to fill didn't bother them in the least. They also gave countless smaller incentives to smaller businesses that located there, providing them a big unfair advantage to competing smaller businesses who didn't know the right people to be offered those deals.

          If I had my way, there would be a nationwide law that there can be no tax breaks, interest free loans or similar incentives to influence a company's decision where to locate or relocate its facilities. But good luck ever getting that passed, I'm sure the government officials involved are often 'greased' one way or another. Probably sacks of cash are rare, but taking them out for expensive dinner, or a trip to NYC or Hawaii on a "fact finding mission" or season tickets in prime seats to football games, or a management job for their daughter....I'm sure kickbacks are plenty even in the small scale of local stuff. Can't imagine what sort of kickbacks would be at play on the EU level, but I'll bet the officials making tax policy decisions are set for life after they leave their bureaucrat job with bureaucratpay.

          1. MachDiamond Silver badge

            Re: @sjiveson - tax blackmail

            If I had my way, there would be a nationwide law that there can be no tax breaks, interest free loans or similar incentives to influence a company's decision where to locate or relocate its facilities. But good luck ever getting that passed,

            There is a difference between poaching a retail store to move 5 miles (Walmart does this frequently) and inducing a company to locate to a depressed area that has lost some major employers. Detroit/Flint have lost a lot of auto manufacturing as Ford creeps down to Mexico and GM is shifting to China. They have large decaying buildings and ghost residential neighborhoods that they want to reinvigorate. Offering tax incentives, land and other support is a way to get companies to locate to what looks like a bombed out third world country with ghetto-like social problems in place.

            It's would be hard to create regulations that prohibited companies from relocating or cities/states from offering inducements to companies to locate operations is their area. Poaching can be a problem, but what do you say to a company being recruited to move from a high tax/high regulation state like California to a state with much lower taxes and a pro-business mentality?

            Apple, Google and Starbucks should combine forces and purchase their own country to base operations. I'm sure they could find a nice island with beautiful beaches and book nearly all of their profits there. People would be lined up to work there.

            1. Anonymous Coward
              Anonymous Coward

              Re: @sjiveson - tax blackmail

              Apple, Google and Starbucks should combine forces and purchase their own country to base operations.

              A simple solution to counter that would be for countries to institute a tariff or sales/VAT tax, applied only to the products of companies based in that special corporate country.

      4. Anonymous Coward
        Anonymous Coward

        Re: Just dumb

        And where could those multinationals go inside EU? The standard tax rate in Ireland is still one of the lowest, and there are no many other places to go. East Europe? Far less appealing for most high-paid executive and upper level employees. which may not like to be sent to Bulgaria or the like.

        Good only when you need low-paid workforce - Dell already moved its EU operations from Ireland to Poland because it was cheaper there to customize servers and PCs.

        And if they move outside the EU, they lose all the advantages of having an EU headquarter - EU is still a big, rich market.

      5. Anonymous Coward
        Anonymous Coward

        Re: Just dumb

        hold the door open while the multinationals leave

        Where? There are only 2 countries with slightly lower tax rates in the Eu than Ireland - Bulgaria and Romania (10% vs Irish 12.5%).

        Sure, Apple and Google may stop routing his Australian sales via Ireland + Singapore (as they do now), but there is no place they can run as far as their Eu income is concerned and the commission is 100% within their rights to enforce that it is taxed.

        1. Andrew Dancy

          Re: Just dumb

          I'm pretty sure you'll find Romania is 16% as they have a flat tax - corporation tax, income tax, tax on self employment, etc are all the same rate - 16%. Nice and simple and virtually impossible to avoid.

          1. Naselus

            Re: Just dumb

            "I'm pretty sure you'll find Romania is 16% as they have a flat tax - corporation tax, income tax, tax on self employment, etc are all the same rate - 16%. Nice and simple and virtually impossible to avoid."

            That'll be why they're such a dominant economic powerhouse then.

  4. Mike Shepherd
    Meh

    Pass me the Kleenex

    "...the EU was seeking to expand its powers over national governments...a devastating blow to the sovereignty of EU member states... Ireland is being picked on and this is unacceptable".

    Oh, worthy man, who sets aside all self-interest to defend the downtrodden countries of the EU!

    Well, maybe not all self-interest.

    1. Missing Semicolon Silver badge
      Facepalm

      Re: Pass me the Kleenex

      "...the EU was seeking to expand its powers over national governments..."

      It already has. What was the Maastricht Treaty, the Treaty of Lisbon, etc all about? The primacy of EU law over member state law is already established.

      That boat sailed decades ago.

      1. Avatar of They
        Facepalm

        Re: Pass me the Kleenex

        Very true, the moment you sign up for a single currency, you pass taxes around that currency to the central area as well. Only right if they control the currency they have a way of determining central tax and interest that might affect that currency.

        Can't have every EU government setting their own versions of that single currency.

        Not sinister as they quite clearly got rid of the irish pound in favour of the Euro. So they kind of walked wide eyed into this. Cook is just panicking at the fact he got caught and will have to pay. But didn't Trump state he might allow them to transfer all that wealth back into the US at a very low one off payment? (might have dreamt it)

      2. Dan 55 Silver badge

        Re: Pass me the Kleenex

        Ireland got an opt out over EU primacy over their tax laws in their Lisbon treaty due to their 'no' answer in the first Lisbon referendum.

  5. Warm Braw

    The EU Commission has sinister plans to control tax rates across the continent

    Whereas that should rightfully be the work of Apple, Amazon, Google, et al.

    1. Commswonk

      Re: The EU Commission has sinister plans to control tax rates across the continent

      Well if it hasn't at the moment it soon will have; I suspect that everybody (except the large corporates) is getting heartily sick of the "now you see it; now you don't" methods of accounting that multinationals use to minimise their contributions to the wider societies in which they operate. The current approach is little short of pillage; grab what you can and disappear as fast as you can, or least make the money disappear so that you are still around to grab any more that happens to come along.

      As the EU Commission has pointed out, this is not a simple matter of tax due on Irish sales as much as allowing other profits to pass through the accounts unchecked. I never thought I would ever raise a cheer for the EU but on this occasion I have made an exception.

      Tim Cook might just find out that the old adage of "there's no such thing as bad publicity" is not universally true.

      I hope...

    2. kmac499

      Re: The EU Commission has sinister plans to control tax rates across the continent

      Well maybe Mr Cook could arrange a meeting with commisioner Vestager at the 'Head Office' in Ireland where all the profits weren't made, with a few interviews with the HQ employees to clarify a few points...

      Shouldn't take too long eh Tim???

      1. Anonymous Coward
        Anonymous Coward

        Mr Cook could arrange a meeting

        Oh, Apple would call its Hollywood friends and setup a whole fake HQ, it would be funny to look at know actors and actress to play the roles of Apple employees...

  6. alain williams Silver badge

    This is an EU matter

    A large part of EU trade rules is to create a level playing field. Sweetheart deals as Eire has done, also with others - not just Apple, benefit Eire at the expense of other countries.

    Individual governments are losing the ability to control the large corporates; it needs something the size of the EU to do it - the USA will not since ''they have the best politicians that money can buy''. The EU also needs to address the imbalance between large and small that allows the large to take the mickey, eg supermarkets paying bills late.

    Unless these behemoths are brought under control we will end up with the large eating the small - the resulting lack of competition will be bad for everyone (except for a few at the top).

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