In brief
Sen. Ron Wyden sent questions to Deloitte, EY, KPMG and PwC about tax planning that uses subsidiaries in Malta.
The inquiry asks whether the firms designed, marketed or earned fees from structures that shift profits to Maltese entities with few or no employees.
The firms have until November 10 to respond. The letters raise questions, but they do not establish that any firm broke the law.
The inquiry starts with nearly empty offices
An office can look real on paper and still have almost nobody inside it. That is the picture behind a new Senate inquiry into Malta tax work by the Big Four accounting firms.
Sen. Ron Wyden of Oregon, the top Democrat on the Senate Finance Committee, sent questions to Deloitte, EY, KPMG and PwC. He wants to know whether they helped large companies move profits into Maltese subsidiaries and lower their tax bills.
The concern is not simply that a company has an operation in Malta. It is whether the profits parked there match the people and business activity actually taking place there.
Wyden wants the playbook, not a short answer
In the letter to Deloitte, Wyden asks seven detailed questions. He wants descriptions of any Malta structures the firm built for U.S. clients, plus copies of presentations, white papers, memos and other marketing material.
He also asks how many clients paid for the work and how much fee revenue it produced. Other questions cover work with Maltese law firms, tax advisers and government officials.
The deadline is November 10. Until the firms respond, the public record does not show the full mechanics, the client count or the fees involved.
Two tax ideas sit at the center
Wyden's letter points to what it calls "round tripping" and "global blending." Those labels can sound more precise than the public facts allow.
In plain terms, the inquiry is about whether income earned by a multinational group can be routed through foreign entities and combined with taxes paid in different countries. That mix may reduce the amount of U.S. tax due, depending on the structure and the rules that apply.
The letter says firms marketed arrangements that used financing entities in Malta and assigned profits to Maltese companies with little or no staff. It also asks whether the advice was designed to reduce taxes under the global minimum tax system known as Pillar Two.
That is an allegation being examined, not a final finding. A foreign subsidiary is not automatically improper, and a low tax bill alone does not prove abuse.
Why accounting firms should watch the response
The questions go beyond tax law. They reach the sales process around aggressive planning: who created the slides, what the claims promised, how benefits were measured and what fees the work generated.
That matters for firms of every size. A planning idea can create legal, reputational and documentation risk long after the first presentation. Marketing language that sounds clever in a pitch deck may look very different when a congressional committee asks for it.
The Big Four responses could show whether the inquiry is aimed at a narrow set of client arrangements or a broader consulting practice. For now, the most important date is November 10, when Wyden expects the firms to explain what work they did and how the structures were supposed to work.
