 The CAIA tool enabled Apple to write-off the US$300 billion price as a capital allowance against future Irish profits (e.g.the next US$300 billion of profits Apple books in Ireland are free of Irish tax).The CAIA "capitalises" the effect of the Double Irish or Single Malt BEPS tools, and behaves like a corporate tax inversion of a U.S. multinational's non–U.S.