On 14 August 2013, the Argentine Federal Tax Court gave its decision in Molinos Rio de la Plata S.A., specifically, on whether dividends paid by a Chilean holding company to a company resident in Argentina were exempt from tax in Argentina under the Argentina - Chile Income and Capital Tax Agreement (1976) (the Treaty). Details of the case are summarized below.
(a) Facts. Molinos, an Argentine resident company in the food processing business, started an international business expansion …