U.K.'s HMRC tax authority is arguing in a London court that General Electric (GE +1.2%) knowingly failed to indicate the purpose of an Australian investment during tax settlement talks in 2005 and made a "deliberate decision" to provide information that was "simplified" and "misleading."

HMRC says the transaction was part of a refinancing operation where GE routed as much as $4.9B between subsidiaries in several countries, which the agency says was a deliberately misleading effort to gain a tax advantage.

GE denies wrongdoing, and says HMRC is trying to change its arguments now that the case has reached court.

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