US Senator Ron Wyden has launched an inquiry into whether Deloitte, EY, KPMG and PwC helped multinational corporations use Maltese subsidiaries to reduce their tax liabilities by billions of dollars.
In letters sent to the four firms on 21 October, Wyden, the senior Democrat on the Senate Finance Committee, requested detailed information about their involvement in developing, marketing and implementing tax-planning arrangements involving Malta.
The inquiry follows an August investigation by The New York Times, which reported that major US corporations had established Maltese subsidiaries to shift profits from higher-tax jurisdictions, sometimes operating through offices with little or no physical business activity.
The newspaper identified footwear company Crocs among the businesses using such arrangements. It also reported reviewing a KPMG presentation outlining a strategy for reducing exposure to the OECD’s 15% global minimum corporate tax.
Firms Asked to Disclose Fees and Tax Strategies
Wyden wants the firms to disclose whether they developed tax structures involving Maltese subsidiaries, advised clients on reducing liabilities under international minimum-tax rules, or produced marketing materials promoting such arrangements.
He has also requested details of the number of clients using these services, the fees generated and any estimates of tax savings achieved.
The inquiry extends to the firms’ relationships with Maltese law firms, tax advisers and government officials involved in establishing or implementing the arrangements.
Wyden expressed concern that major US professional services firms were profiting from aggressively marketing Malta-based tax strategies to corporate clients.
All four firms have been asked to respond by 10 November 2026.
Scrutiny of Big Four Tax Advice
The inquiry raises questions about the commercial role of professional services firms in developing structures designed to exploit differences between national tax systems.
Big4News has previously examined a separate US tax-planning dispute involving PwC, in which the firm’s advisers described a proposed strategy as highly aggressive while helping the client proceed.
The Senate’s latest inquiry does not establish that any of the four firms acted unlawfully. The central questions are what advice they provided, how extensively the structures were marketed and how much revenue the firms generated from the arrangements.
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About the author: Claudine Cassar is the founder and editor of Big4News, covering audit, consulting, regulation and governance across Deloitte, PwC, EY and KPMG.