Peter Macdiarmid/Getty Images(DUBLIN) — Ireland will appeal the European Union’s order to Apple requiring the company to pay $13.57 billion in back taxes to the Irish government, according to the country’s department of finance.

Apple, which runs its European business out of Ireland, was hit with the order in August after a three-year investigation into the iPhone-maker’s tax dealings in Europe, a decision the company said it would also appeal.

The European Commission (EC), the executive branch of the EU, claimed Ireland had given Apple unfair tax advantages as it conducted its business in Europe through two fully-owned companies, Apple Sales International and Apple Operations Europe, with most profits allocated to a “head office” with not physical location. The country was charging Apple for its business in Ireland, not profits across Europe, with a 1 percent tax rate in 2003 and later a rate as low as 0.005 percent in 2014, according to the commission.

Ireland published arguments Monday saying that the EC was attempting to “rewrite the Irish corporation tax rules” and it would appeal to overturn the decision. The department of finance said “all important decisions” from the Cupertino, California-based company’s two branches were made in the U.S. and any “profits deriving from these decisions were not properly attributable” to ASI and AOE.

“Ireland did not give favourable tax treatment to Apple – the full amount of tax was paid in this case and no State aid was provided.  Ireland does not do deals with taxpayers,” said a statement from Ireland’s department of finance.

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