53The specific objective of the exception is not to counter purely artificial arrangements and the application of that exception is not limited to such arrangements. As the Tax Agency acknowledged in essence at the hearing, the exception in question relates to debts resulting from civil-law transactions, not relating solely to fictitious arrangements. Consequently, according to the Tax Agency’s assessment of the objectives of the transaction at issue, the exception may also cover transactions carried out on an arm’s-length basis, that is to say, in conditions analogous to those which would apply between companies which are independent of one another.