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 Arge…

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