Quotation Screpante, Mirna Solange. 2019. Argentina: Non-discrimination. Pirelli Neumáticos SAIC Case. Conference Tax Treaty Case Law around the Globe 2018, Tilburg, Netherlands, 24.05-26.05.18.




Legal issue Whether article 25 of the Treaty requires that a deduction be allowed for royalty payments made by a resident company (Pirelli) to a non-resident company (Pirelli Pneumatici SpA), even if the agreement concerning the transfer of technology has not been approved by the National Institute of Industrial Property (INPI). On 2 September 1999, Pirelli Neumáticos (the taxpayer), a company resident in Argentina, entered into an agreement to license patents and obtain technical assistance from Pirelli Pneumatici SpA, a company resident in Italy. According to the Law 22,426 of Transfer of Technology (LTT), which regulates the transfer of technology regime, contracts between related parties concerning a "transfer of technology", as defined by the law, must be submitted to the National Intellectual Property Institute (Instituto Nacional de la Propiedad Intelectual, INPI), which is the government agency responsible for applying the regime.


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Publication's profile

Status of publication Published
Affiliation WU
Type of publication Paper presented at an academic conference or symposium
Language English
Title Argentina: Non-discrimination. Pirelli Neumáticos SAIC Case
Event Conference Tax Treaty Case Law around the Globe 2018
Year 2019
Date 24.05-26.05.18
Country Netherlands
Location Tilburg


Screpante, Mirna Solange (Former researcher)
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)
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