Ireland said on Tuesday it was not to blame for Apple Inc's low global tax payments after the US Senate said the company paid little or nothing on tens of billions of dollars in profits stashed in Irish subsidiaries.

The Irish government, which has seen the luring of US multinationals with low taxes as a key part of its economic policy since the 1960s, said its system was transparent and other countries were responsible if the tax rate paid by Apple was too low.

"They are issues that arise from the taxation systems in other jurisdictions, and that is an issue that has to be addressed first of all in those jurisdictions," Deputy Prime Minister Eamon Gilmore told national broadcaster RTE on Tuesday.

In a 40-page memorandum released ahead of an appearance by Apple Chief Executive Tim Cook before the US Congress on Tuesday, a Senate subcommittee identified three subsidiaries that have no tax residency either in Ireland, where they are incorporated, or in the US, where those companies are managed.

The main subsidiary, a holding company that includes Apple's retail stores throughout Europe, has not paid any corporate income tax in the last five years, the report said.

Apple's arrangement has allowed it to pay just 1.9 percent tax on its $37 billion in overseas profits in 2012, despite the fact that the average tax rate in the countries of the Organization for Economic Cooperation and Development (OECD), its main markets, was 24 percent in 2012.

The report said "Ireland has essentially functioned as a tax haven for Apple."

Gilmore said Ireland was pursuing the issue of international tax avoidance "very strongly" at the European Union and the OECD, which is spearheading initiatives.

The US Senate report said a subsidiary with a mailing address in Cork, Ireland's second-largest city, received $29.9 billion in dividends from lower-tiered offshore affiliates from 2009 to 2012, comprising 30 percent of Apple's global net profits.

It said it exploited a difference between Irish and US tax  rules.

Apple said in a comment posted online on Monday it did not use "tax gimmicks."

It said the existence of its subsidiary Apple Operations International in Ireland did not reduce Apple's US tax liability and the company would pay more than $7 billion in US taxes in fiscal 2013.

A number of US multinationals including Web search leader Google, online retailer amazon.com and coffee chain Starbucks have come under criticism for arranging their affairs in a way that leaves them liable to low rates of tax on billions of dollars of overseas sales.