Wyden Probes ‘Big Four’ Accounting Firm CEOs On Offshore Tax Shelter Consulting

Wyden Probes 'Big Four' Accounting Firm CEOs On Offshore Tax Shelter Consulting

Big Four Accounting Firms Have Reportedly Advised Clients to Use Maltese Tax Shelters to Avoid Billions in Taxes

Washington, D.C. - Senate Finance Committee Ranking Member Ron Wyden, D-Ore., today launched an inquiry into reports of the "big four" accounting firms advising major clients in the United States and European Union to create tax shelters in Malta to avoid paying billions in taxes.

In letters to the CEOs of the "big four" accounting firms, PWC, KPMG, Deloitte and EY, Wyden requested information about the firms' roles in devising strategies for large multinational corporations to exploit international tax loopholes.

"For several years now I have been conducting an investigation into the means by which multinational corporations use subsidiaries in jurisdictions treated as foreign for tax purposes to avoid paying billions of dollars in U.S. taxes," Wyden argued in the letter to CEO's of the "big four" accounting firms. "I am concerned that large U.S. professional services firms are profiting off aggressively marketing these Malta-based tax strategies to large corporations."

The tax loopholes that these giant corporations are exploiting were made possible by the 2017 Republican tax law that enabled loopholes such as "round-tripping" and "global trending," which enabled corporations to avoid billions in taxes.

This summer, an independent investigator from the New York Times visited an office building in Malta where many of the "big four" clients have set up subsidiaries. Upon arriving, the investigator only found empty offices, with the lights off and little to no employees. This scheme to use employee-free shell companies in Malta to artificially drive down taxes merits further investigation.

"I have long been concerned by the extent to which schemes such as 'global blending' and 'round tripping' are being used by multinational corporations to shift profits offshore. While working class Americans dutifully pay taxes on every paycheck, sophisticated accountants and tax lawyers are devising clever strategies for corporate giants to continue exploiting offshore tax havens to avoid paying their fair share," said Wyden.

In the letter, Wyden requested that CEO's of these accounting firms answer the following questions by no later than November 10, 2026.

1. Has [your firm] worked with U.S. corporate clients to develop and implement tax planning structures involving subsidiaries in Malta and allocating profits to subsidiaries in Malta? If yes, please describe these structures in extensive detail and how they help U.S. multinational corporations reduce their tax liabilities in the U.S. or globally.

2. Has [your firm] advised corporate clients that U.S. or European multinational clients can use Maltese entities to avoid or reduce U.S. or foreign taxes, including those put in place under the Pillar 2 global minimum tax system? If yes, please describe how.

3. Has [your firm] ever prepared any presentations, slide decks or other marketing materials (such as white papers, memoranda or legal briefs) for U.S. multinational corporate clients describing tax strategies involving the use of Maltese entities? If yes, please provide copies of these documents, with redactions of personally identifiable information or other data that would reveal the identity of the client(s).

4. Has [your firm] ever memorialized in written materials the extent to which tax strategies involving Maltese entities have helped, or can help, U.S. multinational corporations reduce U.S. or foreign tax liabilities? If yes, please provide any documents outlining how much in U.S. corporate income taxes, other U.S. or non-U.S. tax liabilities, U.S. clients have avoided paying, or would expect to avoid, as a result of tax planning strategies involving Maltese entities.

5. Has [your firm] generated any fees devising or marketing tax planning strategies involving Malta to U.S. multinational corporations? If yes, please provide the number of clients who have paid for these services as well as the total dollar amount of fees these services have generated.

6. Has [your firm] ever worked with any local Maltese law firms or tax advisers to help U.S. multinational corporations devise or implement tax reduction strategies involving the use of Maltese subsidiaries? If yes, please describe these efforts.

7. Has [your firm] ever worked with Maltese government officials to devise or implement strategies to help U.S. multinational corporations implement tax reduction strategies involving the use

The text of the letter to Deloitte is here.

The text of the letter to EY is here.

The text of the letter to KPMG is here.

The text of the letter to PWC is here.

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