Screpante, Mirna Solange. 2018. Argentina: Treaty Abuse and Beneficial Ownership-the Molinos Case. In: Tax Treaty Case Law around the Globe 2017, Hrsg. Lang et al, 115-130. Vienna: IBFD.

RIS

@INBOOK{Screpante2018,
title = {Argentina: Treaty Abuse and Beneficial Ownership-the Molinos Case},
author = {Mirna Solange Screpante},
publisher = {IBFD},
year = {2018},
address = {Vienna},
publisher = {IBFD},
language = {EN},
pages = {115-130},
series = {Tax Treaty Case Law around the Globe 2017},
abstract = {The Molinos Argentina vs. DGI case addresses an alleged treaty shopping practice that involved the establishment of a holding company in Chile through which dividends from subsidiaries in other countries – in this case, located in Peru and Uruguay– would be passed to Argentina, presumably to benefit from a combination of a special regime in the Chilean domestic law and the Argentina-Chile Income and Capital Tax Treaty (1976) (hereinafter the Argentina-Chile tax treaty) in force at that time which lead to a double non-taxation phenomenon. },
}