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Argentina Supreme Court Rules Domestic GAAR May be Applied to Deny Treaty Benefits

|Treaty Development|Argentina-Chile
Argentina-Chile

Argentina's Supreme Court issued its decision on 2 September 2021 concerning whether Argentina's domestic general anti-abuse rules may be applied to deny the benefits of an income tax treaty that does not contain anti-abuse rules itself. The decision was issued by a majority, with one judge dissenting.

The case involved an Argentina taxpayer, Molinos Argentina, that established a holding com…

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