In the UK, high street retailer Marks and Spencer (M&S) has come under fire from tax campaigners over the way it structures its online sales to Europe, which critics say is using a similar 'transfer pricing' approach to that employed by Amazon.

The new M&S online site for sales in Europe processes orders from customers in France, Germany, Ireland or other countries from its UK warehouses, but all transactions are made with, and charged to, Marks & Spencer (Ireland) Ltd, a subsidiary located in the Republic of Ireland, which has the lowest corporation tax rates in Europe.

M&S's UK branch is paid a wholesale price for the goods it ships by M&S Ireland, and this is subject to UK corporation tax, but the rest of the retail markup is subject to Ireland's much lower corporation tax rate of 12.5%, according to an investigation by the Guardian.

Speaking at the M&S AGM yesterday, CEO Marc Bolland said there was 'nothing fiscal' in the company's use of Ireland as a trading hub for its international e-commerce business, as the country now handles more than 50% of its online European sales. Ireland is also the largest international market for M&S.

Bolland said: 'M&S pays UK corporation tax on all the profits generated by UK sales. We contributed £800m to the UK tax authorities in 2011-12 - the 25th highest tax contributor in the UK.'

At the AGM, M&S reported that annual profits had fallen to their lowest point in four years. The underlying pre-tax profit for 2012/13 was down 6% on the previous year, at £665.2m, below City forecasts for £710m.