UMJ borrowed 80 billion yen ($1 billion) from an affiliate in France during its restructure in 2008 and declared 9 billion yen it paid in interest to the French company as an expense.

But the Tokyo Regional Taxation Bureau believes the interest payment was an attempt to avoid taxes.

It is said to have ordered UMJ to pay 3 billion yen ($37.9 million) in back taxes and penalties.

UMJ has appealed to the National Tax Tribunal and released the following ...