Milan/Paris — Italian tax authorities say Fiat Chrysler underestimated the value of its American business by €5.1bn after its phased acquisition several years ago, presenting the vehicle maker with a potentially hefty bill as it prepares to merge with French rival PSA.

The dispute relates to the company structure created in October 2014 after Fiat’s purchase of the remainder of its Chrysler unit, according to company filings and an October 22 audit report seen by Bloomberg. The purchases stretched over five years and culminated in the full takeover of the once-bankrupt owner of brands such as Dodge, Ram and Jeep...

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