This article analyses whether a loan received by an Argentinian taxpayer, Transportadora de Energia SA, from a related company located in Brazil, CIEN SA, should be recharacterized as capital contributions due to the inability of the borrower to pay the maturities during the economic downturn of 2001. The importance of the case lies in the fact that the economic and financial crisis in Argentina 20 years ago has many parallels with the problems that the world is facing today with the COVID-19 pandemic.