Quotation 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.


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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.

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Publication's profile

Status of publication Published
Affiliation WU
Type of publication Chapter in edited volume
Language English
Title Argentina: Treaty Abuse and Beneficial Ownership-the Molinos Case
Title of whole publication Tax Treaty Case Law around the Globe 2017
Editor Lang et al
Page from 115
Page to 130
Location Vienna
Publisher IBFD
Year 2018
Open Access N

Associations

People
Screpante, Mirna Solange (Former researcher)
Organization
Austrian and International Tax Law IN (Details)
Research areas (ÖSTAT Classification 'Statistik Austria')
5261 Comparative constitutional law (European -, international -) (Details)
5349 Business taxation (Details)
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