OrbitaxTax treaty between Argentina and Italy – Argentine Court decision on application of the non-discrimination clause
|Treaty Development|Argentina
On 23 May 2013, the Court of Appeals (Cámara Nacional en lo Contencioso Administrativo Federal) gave its decision in Pirelli Neumáticos SAIC, specifically, on the application of the non-discrimination clause of the Argentina - Italy Income and Capital Tax Treaty (1979) (the Treaty). Details of the case are summarized below.
(a) Facts. On 2 September 1999, Pirelli, a resident compan…
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