Digitalization And Tax Law 2023

S. 351Determination of Correct Interest Rates for Intra-Company Loans by using an AI-based Algorithm

Gregor E. Appeltauer

S. 3531. Introduction

Technology is on the rise. Everywhere. And, as some unscrupulous union bosses, “concerned” politicians, and movies might suggest, it will be dreadful, dreary, and murderous. In fact, mankind had to be saved already repeatedly over the last decades, with movie interpretations including Arnold Schwarzenegger fighting a series of killer cybernetic organisms, Will Smith clashing with the NS-5, and Keanu Reeves battling machinery in general.

A substantially less funny, real situation featured Soviet Air Defence Forces Lieutenant Colonel Stanislav Petrov ignoring a newly introduced computer system’s early-warning alarm in 1983 that had detected an incoming American nuclear missile launch. Had Petrov informed his superiors, Soviet procedures had foreseen an automatic retaliatory strike – and nuclear Armageddon. Fortunately, Petrov mistrusted the system, and remained idle.

Figure 1: The fearsome NS-5 [based on 20th Century Fox, ‘I, Robot’, 2004, https://imgl.krone.at/scaled/2489382/v8376d8/schema_org_16_9.jpg (accessed 12 September 2021)]

But technology does not hav...