Apple will challenge a €13-billion (approximately Rs 92,141.27 crore) tax ruling by the European Union later this week in the body’s second-highest court, Reuters reported. In August, the European Commission had directed the company to pay the amount plus interest after ruling that it had illegally gained from a “selective tax treatment” in Ireland.

Calling itself a “convenient target” for tax authorities in the EU, the company said regulators ignored tax experts and corporate law by imposing the maximum possible penalty. Company General Counsel Bruce Sewell said the company had been singled out because of it success.

“Apple is not an outlier in any sense that matters to the law,” Sewell said. “Apple is a convenient target because it generates lots of headlines.” The company will tell judges at the court that the European Commission did not diligently conduct the investigation because it disregarded opinions by tax experts, he said.

“The Commission not only didn’t attack that – didn’t argue with it, as far as we know – they probably didn’t even read it [the opinion].” Sewell added that it was not possible for Apple to comply with the EU’s decision as it meant that Ireland would be violating its own tax laws.

The Irish government, too, is appealing against the ruling, and the United States has accused the EU of attempting to retain money meant for its tax and revenue purposes. In August, the European Commission had said that Ireland’s favourable tax policy gave the world’s richest company a “significant advantage over other businesses.” The penalty is the regulator’s biggest decision in a three-year concentrated campaign against tax favouritism.