The Netherlands Supreme Court recently issued its ruling on whether the business motive test applies for all transactions in an offshore re-routing of funds as it applies for the deduction of related party interest expense. The case concerned two Dutch resident subsidiaries that acquired funds from a related Mauritian financing company for the purpose of making several participation acquisitions. The funds lent from the Mauritian company had originated from the issuance of shares by the parent company of the group, the proceeds of which had been lent to a South African resident holding company, were then contributed to a Mauritian...