Apple has claimed that the European Commission's investigation into its tax payments in Ireland was flawed.
It believes that the Commission made "fundamental errors" during the probe and that additional evidence should have been examined.
The US firm has issued a 14 point appeal against the EU's findings.
Its primary argument is that activities relating to the creation of new IP happened in the US. "The profits from those activities are attributable to the US, not Ireland," the appeal states.
The Irish Government will also appeal against the decision, which would result in the US firm paying some €13bn in back taxes.
It says that the EU, "failed to recognise that the Irish branches carried out only routine functions and were not involved in the development and commercialisation of Apple IP, which drove profits."
It also writes that the EU has overstepped its powers and that it is, "attempting to redesign Ireland’s corporate tax system."
European competition commissioner Margrethe Vestager recently addressed the Oireachtas Committee on Finance, Public Expenditure and Reform and defended the EU's ruling, saying that there is no "witch hunt" against US corporations and that the findings are, "based on principles that have been part of the law for many years."