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 subsidized.

The submission by the Dubai-based carrier, the world's biggest international airline by traffic, shifts the focus of the global airline spat to U.S. officials who now 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 monthslong verbal sparring between America'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.

Speaking to reporters in WashingtonSHY after meeting U.S. governmentSHY representatives, he called his rivals' assertions "a mess of legal distortions and factual errorsSHY."

Emirates' move comes after Delta Air Lines Inc., United Continental Holdings Inc. and American Airlines Group Inc. in January issued a 55-page report accusing the three Persian Gulf carriers of collectively receiving $42.3 billion in subsidies. The U.S. airlines called on the U.S. government to curb their rivals' growth through changes to bilateral "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.

The Gulf carriers have said they are commercial enterprises that aren't state subsidized.

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, which have also lobbied for curbs on the Persian Gulf rivals.

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. The carriers also have the support of delivery companies, such as FedEx Corp., which have large logistics hubs in Dubai.

Emirates 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 the U.S. carriers argued the low charges at Dubai International Airport that serves as Emirates's hub were effectively a subsidy. Airports in Pittsburgh and Portland, Ore., 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, according to the Gulf carrier.

Delta declined to address the specific allegations. United didn't immediately respond to request for comment.

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 U.S. 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. The carrier said its rivals are invoking international trade rules that don't apply to air transport.

"Emirates can submit as many pages as it wants," said Jill ZuckmanSHYSHY, a spokeswoman for the U.S. airlines' coalition, called Partnership for Open & Fair Skies. "But it still won't paper over what has been well-documented: Emirates has received billions [of dollars] in subsidies and unfair benefits from the treasury of the U.A.E."

Another persistent claim against the Middle East carrier has been that 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.

Whether 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 U.A.E. and Qatar over the open skies air treaties.

American Airlines Chief Executive Doug Parker said in June that he expected the U.S. government to take action soon.

Emirates' Mr. Clark, who previouslySHY said he expected existing open skies accords to remain intact, said on Tuesday that he expects the U.S. government to start reviewing the evidence in July or August beforeSHY deciding on whether to act.

Susan Carey contributed to this article.

Write to Rory Jones at rory.jones@wsj.com and Robert Wall at robert.wall@wsj.com

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