By Rory Jones in Dubai and Robert Wall in London 

Emirates Airline has submitted a 388-page document to the U.S. government that aims to rebut accusations by North American rivals that it is unfairly subsidized.

The submission by the Dubai-based carrier shifts the focus of the global airline spat to U.S. officials who know have to decide whose arguments are more persuasive.

The document, which Emirates presented to the U.S. government on Monday, represents the most detailed argument yet by one of the rapidly growing Middle East carriers in defense of its business practices. It follows months-long verbal sparring between the U.S.'s three major carriers and the three biggest Persian Gulf rivals: Emirates, Abu Dhabi-based Etihad Airways and Qatar Airways.

"We are absolutely not subsidized, and our operations don't harm these legacy carriers, but instead benefit consumers, communities and America's national economy," Emirates President Tim Clark said in a statement.

Emirates' move comes after Delta Air Lines, United Airlines and American Airline in January issued a 55-page report accusing the three Persian Gulf airlines of collectively receiving $42.3 billion in subsidies. The airlines called on the U.S. government to curb their rivals' growth through changes to bilateral so-called Open Skies agreements that liberalized air travel.

The U.S. government early on said it took the allegations seriously and asked the three U.S. airlines for additional information, which they supplied. The departments of Transportation, State and Commerce opened up regulatory dockets where interested parties can post comments and documents.

Etihad supplied its rebuttal to the U.S. claims in early June. Doha-based Qatar Airways hasn't produced a document, but has dismissed the U.S. claims in numerous public comments. It declined to comment.

The U.S. airline trio is supported by pilot unions and European carriers such as Air France-KLM SA and Deutsche Lufthansa AG, who have lobbied far longer for curbs on their Persian Gulf competitors. The Middle Eastern airlines have secured the backing of travel agency representatives, which argue the airlines offer a higher-quality of service than their U.S. peers. They also have the support of delivery companies, such as FedEx Corp., which have large logistics hubs in Dubai.

Emirates, the world's biggest international carrier by traffic, in its submission to the U.S. government seeks to counter allegations made by its rivals on a mix of financial and legal grounds. In several cases, the Dubai-based carrier asserted that its U.S. rivals have benefited from many of the same business practices that they denounce as subsidies.

The U.S. carriers accused Emirates of transferring a large liability on fuel bets off its books in 2008 to mask losses in what amounted to a government subsidy. Emirates said the losses were never realized. The mark-to-market accounting losses would have distorted Emirate's operational performance, the carrier said, adding that the Dubai government received a financial gain when fuel prices rebounded. Delta employed a similar accounting approach in its 2009 results, Emirates said.

Emirates also said U.S. airlines struck advantageous deals with airports even as its rivals argue low charges at the Dubai International airport that serves as Emirates's hub were effectively a subsidy. Airports in Pittsburgh and Portland granted Delta preferential financial terms to secure its business and Denver airport in 2014 extended incentives to United to ensure the U.S. carrier wouldn't cease its hub operations there, the Gulf carrier said.

The most expansive element of the rebuttal deals with the Open Skies agreement between the U.S. and United Arab Emirates, which effectively allows Emirates to fly to any point in the 50 states. The U.S. carriers argue those traffic rights should be curtailed because Emirates and its neighbors are violating the spirit of the law.

Emirates denies the accord is being violated. Its rivals are invoking international trade rules that don't apply to air transport, it said.

Critics dismissed its arguments. "Emirates can submit as many pages as it wants," said Jill Zuckman, spokeswoman for the U.S. airline's coalition. "But it still won't paper over what has been well-documented: Emirates has received billions in subsidies and unfair benefits from the treasury of the U.A.E."

Another persistent claim against the Middle East carrier has been they are paying artificially low prices for fuel. Emirates said it pays less for its jet fuel at U.S. airports than it does at home, including from the national oil company.

How and when the U.S. government will act is unclear. The three U.S. carriers have requested the U.S. pursue consultations with the governments of the United Arab Emirates and Qatar over the Open Skies air treaties.

American Airlines Chief Executive Doug Parker said this month he expected the U.S. government to take action soon. Mr. Clark said previously he expected existing Open Skies accords to remain intact.

--Susan Carey contributed to this article

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