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.
BibTeX
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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| 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
- Institute for Austrian and International Tax Law IN (Details)
- Research areas (ÖSTAT Classification 'Statistik Austria')
- 5261 Comparative constitutional law (European -, international -) (Details)
- 5349 Business taxation (Details)