LONDON, May 21 (Reuters) - Apple’s ability to shelter billions of dollars of income from tax has hinged on an unusual loophole in the Irish tax code that helps the country compete with other countries for investment and jobs.

A U.S. Senate investigation has revealed that Apple, maker of iPhones, iPads and Mac computers, had channelled profits into Irish-incorporated subsidiaries that had “no declared tax residency anywhere in the world”.

Apple tax head Phillip Bullock told the Senate Permanent Subcommittee on Investigations on Tuesday that one of those companies, Apple Operations International (AOI), though it was functionally managed in the United States, had not submitted a tax return anywhere for five years.

It is not clear if the tax status of AOI was part of the negotiations with the Irish government through which Bullock told the committee that, “under the agreement we have with Ireland”, Apple paid a maximum tax rate of 2 percent or less.

Apple’s annual reports show that over the past three years, Apple paid taxes worth 2 percent of its $74 billion in overseas income.

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See, this is ridiculous, and shows how there is nothing at all “fair” about capitalism. If corporations are people, what kind of person pays less than 2% taxes on $74 billion in wealth? I pay like 20% taxes on income that is hardly a measurable fraction of that amount of wealth!