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 company in Chile that received dividends from foreign subsidiaries in Peru and Uruguay, which were exem…