The Court of Justice of the European Union (CJEU) on 24 February 2022 issued its decision in the Viva Telecom case. The case concerned a Bulgarian company that contracted a convertible interest-free loan from its sole Luxembourg shareholder. The contractual terms provided for the repayment of the principal after 60 years unless the shareholder contributes the loan to the capital of the debtor. Following a tax audit, the Bulgarian tax authorities imputed an arm's length interest expense that should have been paid on the loan and reassessed the debtor company for failure to withhold tax on the interest so imputed....