Defense in a dispute over the tax fate of interest on intra-group cross-border loans

Even at the pre-trial stage of a tax dispute, a world-famous manufacturer of machinery was able to defend a world-famous manufacturer of machinery against claims to interest on intra-group loans related to an attempt to reclassify them as hidden dividends on the basis of arguments about the artificial nature of the debt, since the loans were used to cover “cash gaps”, including intra-group transactions.