This dispute concerned eight financial, taxation, foreign exchange, and registration measures imposed by Argentina, mostly on services and service suppliers from countries that do not exchange information with Argentina for the purposes of fiscal transparency (non-cooperative countries). In particular, these measures concerned: withholding tax on payments of interest or remuneration; presumption of unjustified increase in wealth; transaction valuation based on transfer prices; payment received rule for the allocation of expenditure; requirements relating to reinsurance services; requirements for access to the Argentine capital market; requirements for the registration of branches; and foreign exchange authorization requirement.

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