Ireland's finance ministry said its position remained that the full amount of tax was paid and no state aid was provided. Ireland did not give favorable tax treatment to Apple and does not do deals with taxpayers, it added.

It also said the disputed tax opinions in the Apple case no longer applied and that the decision had no effect on Ireland's 12.5 percent corporate tax rate or on any other company with operations in the country.

"I disagree profoundly with the Commission," Noonan said in a statement. "The decision leaves me with no choice but to seek cabinet approval to appeal. This is necessary to defend the integrity of our tax system; to provide tax certainty to business; and to challenge the encroachment of EU state aid rules into the sovereign member state competence of taxation."

(Reporting by Padraic Halpin; Editing by Mark Potter)