U.S. Tariff Refunds for European Companies

Introduction

Following the U.S. Supreme Court's February 2026 ruling on tariffs imposed under the International Emergency Economic Powers Act (IEEPA), U.S. Customs and Border Protection established a process for issuing qualifying IEEPA tariff refunds.

Receiving a U.S. tariff refund can present a practical challenge for companies based outside the United States due to U.S. Customs requirements governing how tariff refunds are issued. To receive the refund electronically, the recipient is required to have access to a U.S.-domiciled, USD-denominated account capable of receiving ACH payments (ACH ‘Push”)..

For many European companies particularly, this creates a significant obstacle. As these companies are typically not registered entities in the United States, they may not have the appropriate U.S. banking infrastructure to receive the funds directly.

Corpay can help bridge this gap for eligible European companies with a Multi-Currency Account (MCA) solution capable of receiving the USD refund via ACH Push.

The following addresses the questions we hear most frequently in our discussions with clients (and prospective clients) about this topic.

Can the U.S. tariff refund be paid directly to our European bank account?

Generally, no. Under the U.S. Customs refund process described above, the refund must be paid into a U.S.-based, USD-denominated account capable of receiving ACH payments.

This creates a challenge for many European companies which generally do not have access to the type of U.S.-based bank account required to receive the refund directly.

Does the refund have to be paid to the company or branch that originally paid the tariff as importer of record (IOR)?

Yes. As a general rule, the tariff refund is issued to the importer entitled to the refund, subject to applicable CBP procedures for designated third parties.

Thus if the non-US parent company is the importer entitled to the refund, the existence of a U.S. subsidiary or affiliate does not, by itself, allow the refund to be redirected to that subsidiary.

This creates a practical challenge when the parent company does not have the appropriate U.S.-based, USD-denominated account capable of receiving ACH payments (as the CBP requires).

What if our company does not have a U.S. bank account?

This is precisely where the Corpay solution can help.

If the parent company entitled to the refund does not have the U.S.-based USD account required to receive the payment, Corpay can help address this issue by establishing, for eligible companies, a Multi-Currency Account (MCA) in the name of the legal entity entitled to the refund (subject to applicable onboarding and compliance requirements).

Corpay’s Multi-Currency Accounts solution includes a US-based, US dollar-denominated collections MCA enabled with ACH Push capability.

This allows the refund to be received in USD by the correct legal entity.

If the MCA is U.S.-based, is the account held in the European company’s name?

Yes. The Multi-Currency Account is established in the name of the European company that is entitled to receive the refund.

The USD Multi-Currency Account (MCA) mentioned above is U.S.-based and provides the functionality required to receive the tariff refund.

Once the tariff refund has been credited to the MCA, the funds are held in the MCA in the name of the European company.

Can Corpay handle both receiving the tariff refund and converting the currency?

Yes. This is one of the principal advantages of the solution.

Subject to eligibility and approval, Corpay can provide a structure through which the company may:

1. Establish an MCA with U.S. dollar receiving capabilities;

2. Receive the qualifying tariff refund in USD;

3. Convert the USD payment into EUR, GBP, or another supported currency;

4. Transfer the converted funds to the company's designated bank account.

This combines the payment and foreign exchange components into one coordinated process.

Has Corpay successfully done this for a European company?

Yes. Corpay recently assisted an Italian company that needed to receive U.S. tariff refunds.

Corpay opened an MCA for the Italian parent company, allowing the company to receive two separate refund payments, totaling approximately USD 200,000. Once the funds were received, Corpay facilitated the conversion of the U.S. dollars into euros.

This experience helped establish a potential framework that may be applicable to other eligible European companies facing similar payment challenges.

Is this solution only available to Italian or European companies?

No. The solution is not specific to Italy.

Companies in other European markets — including Germany, France, Spain, Portugal, and the United Kingdom — may face similar challenges when receiving U.S. dollar tariff reimbursements.

Other non-US companies outside Europe and the UK may benefit from this solution as well.

Eligibility and account requirements will depend on the company's jurisdiction, corporate structure, payment circumstances, and applicable compliance requirements.

Who should we contact if our company is expecting a U.S. tariff refund?

If your company has been deemed eligible, is expecting, or believes it may be entitled to a U.S. tariff reimbursement, Corpay can review the payment requirements and determine whether an MCA and foreign-exchange solution may be appropriate.

The process would typically begin with understanding:

• Which legal entity paid the original tariff as Importer of Record;

• Which entity is entitled to receive the refund;

• How the U.S. refund will be paid;

• The expected amount and currency;

• Where the company ultimately needs the funds; and

• Whether foreign exchange conversion will be required.

From there, Corpay can determine the appropriate account, payment, and FX structure, subject to eligibility, onboarding, and compliance approval.

How long does it take to open the MCA and be ready to receive the tariff refund?

The company will first need to establish a Corpay account, if it doesn’t already have one.

The time required to establish the account and enable the Multi-Currency Account (MCA) facility can vary depending on the company, its jurisdiction and the completion of the required onboarding and compliance process.

Corpay will work with the European (or other non-US) company to complete the account-opening process as efficiently as possible, particularly when a tariff refund has already been approved or is expected to be issued.

Once the account application and any necessary supporting documents are submitted, the review typically takes only a few business days. From there, enabling MCAs is typically a matter of hours.

Companies that are expecting a U.S. tariff refund are therefore encouraged to contact Corpay as early as possible so that the Corpay account and MCA can be established and ready to receive the funds when the refund is issued.

Are there any restrictions on how long the tariff refund can remain in USD in the MCA?

Once the tariff refund has been received into the U.S.-based USD Multi-Currency Account (MCA), which is established in the name of the European company, there is no requirement to immediately convert the funds into the company’s local currency, subject to the applicable MCA terms and conditions.

The company can choose to retain the funds in USD, and determine when it wishes to execute the foreign exchange transaction based on its own treasury and business requirements.

When the company decides to convert the funds, Corpay can execute the FX transaction from USD into EUR or another supported currency. The converted funds can then be transferred to the company’s designated bank account.

This provides the company with flexibility over both the management of its USD funds and the timing of the currency conversion.

What information does Corpay need to get the process started?

The initial review is straightforward. Corpay will first need to understand the company’s specific circumstances, including:

• The European (or other non-US) legal entity that paid the original tariffs as Importer of Record and is entitled to receive the refund;

• The approximate amount of the expected tariff reimbursement;

• Whether the refund has already been approved or is still being processed; and

• The anticipated timing of the reimbursement, if known.

From there, Corpay can determine whether the company is eligible for the MCA solution and guide it through the required onboarding and account-opening process.

Once the MCA is established, the company will have a U.S.-based, USD-denominated account in its own name.

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