My take here.

Tax again. In this case, "verdeckte Gewinnausschüttungen" (constructive dividends) in the overall context of "Gesellschafterfremdfinanzierung" (thin capitalisation).

The BHF's ruling referred to here is most probably one of a series of rulings on constructive dividends between 1999 and 1996, although these have also been further fleshed out in additional rulings since then. The question at issue here is whether the mere existence of collateral securing an intercompany loan is sufficient to justify the arm's length principle ("Fremdvergleich"). Essentially, what the BHF ruled was that this *might* only be the case if a third-party lender would have demanded collateral in similar circumstances *and* would have no means of otherwise influencing redemption of the loan. There are in fact far more complicated conditions attached, but you'd have to consult the literature to ascertain all the details.

With that context in mind, I think an appropriate translation would be something like:

The Federal Fiscal Court has ruled in this respect that an agreement on the collateralisation of claims under loans does not in itself uphold the arm's length principle.