EU’s Apple Tax Decision Sets Stage for Drawn-Out Legal Battle

The European Commission’s just-released decision telling Ireland to retroactively recoup $14.5 billion in unpaid taxes from Apple Inc. sets the stage for a game of tax chess in the European courts that could go on for years.

Public statements from the central protagonists—the commission, Apple, and Ireland—show the parties wedded to their legal positions with virtually no chance of settlement. The losing party before the EU General Court will almost certainly appeal the decision to the European Court of Justice.

In its decision released Dec. 19, the commission said tax rulings issued by the Irish Revenue to two Apple subsidiaries ...