If a profitable company is making a loan it does not need to a subsidiary it controls, that's a fictive loan used to disguise a transfer.
When licensing costs are paid to a shell company with 3 employees in a country that is neither the place where the HQ are or where the company originates from, that's fictive.
When licensing costs are paid to a shell company with 3 employees in a country that is neither the place where the HQ are or where the company originates from, that's fictive.