Ireland has been told to recoup €13 billion from Apple, after it was found to have given the company special tax treatment.

The European Commission says Ireland made tax rulings which allowed the technology giant to avoid tax over almost 25 years.

Finance minister Michael Noonan has already indicated he will ask the Cabinet to appeal the ruling - while Apple itself has also hit out.

The Commission's basic case is that while the lion's share of Apple's global income is channelled through Ireland - which is fair - Ireland allowed Apple to split this into two piles, funnelling a small portion through a legitimate Irish operation, but sending most of it through an apparent "head office" which existed in law but not in reality.

This head office was not tax resident in Ireland or anywhere else - leading Brussels to conclude that Ireland had granted state aid to Apple by enabling it to avoid taxes on billions of profit.

The €13 billion figure - which does not include interest - reflects the apparent benefit to Apple between 2003 and 2014. The system ended in 2015 when Apple reorganised its subsidiaries. 

However the figure may not all end up in Irish coffers, as Brussels believes some of the money could be claimed by other governments if they make a case that the tax ought to have been paid there in the first place.

Noonan wants to appeal ruling and turn down money

In a statement Michael Noonan said he disagreed profoundly with the decision, and would appeal it - effectively meaning the State is, for now, turning down the €13 billion payment which will be held frozen in an escrow account.

Noonan says Ireland still believes the full tax was paid, no state aid was provided, and Ireland does not do deals with taxpayers.

He says the fact that the tax could be claimed by other countries also undermines the Commission's claim that the money is due to Ireland alone.

He says Apple's ability to avoid taxes in Ireland and elsewhere was the result of a mismatch between international tax laws, which were not Ireland's fault alone.

Apple meanwhile has also claimed the EU is trying to impose its vision of what the law should have been, and not what it is. but CEO Tim Cook says the company remains committed to its Cork operations.

Our political correspondent Gavan Reilly filed this report for Today FM's National Lunchtime News: