CFC rules are applied to the following situations:        
A) A trust located abroad whose main purpose is the management of assets, as long as it is controlled by an Argentine resident. A person shall be deemed to have control when there is evidence that the financial assets are held by and/or managed by that person, including, among others, the following cases:
i) When the trust is a revocable trust.    
ii) When the trustor and the trust’s beneficiary are the same person.     
iii) When the Argentine resident has the right to directly invest or uninvest the assets of the trust.        

B) An entity which is not considered a taxpayer in the foreign country where it is located.

C) An entity which is considered a taxpayer in the foreign country, as long as some requirements take place concurrently. These requirements are:
1) That the Argentine resident has, directly or indirectly, a percentage of ownership equal to or greater than FIFTY PERCENT (50%) in the capital, earnings, or voting rights of the non-resident entity. 
As regards indirect ownership or control, it takes place when the Argentine resident controls the foreign entity through one of these means: (i) An entity which is controlled by or related to the Argentine resident; (ii) their spouse; (iii) their cohabitant; or (iv) Other taxpayers related by blood or marriage, in ascending, descending, or collateral lines, up to and including third-degree relatives.      
This requirement will be considered fulfilled, regardless of the percentage of ownership, when the Argentine resident, directly or indirectly, meets any of the following requirements with respect to foreign entities:
i) holds the right to dispose of the entity’s assets.
ii) has the right to elect the majority of the directors or managers and/or the Argentine resident takes part in the board of directors and has the votes to impose decisions.    
iii) has the votes to dismiss the directors or managers of the entity.    
iv) has a right to the entity’s profits.    
This requirement will also be considered fulfilled, regardless of the percentage of ownership, when at any time during the fiscal year at least 30% of the value of the assets of the foreign entity arises from financial investments that generate passive income from Argentine source considered exempt for foreign beneficiaries.
2) That the non-resident entity does not have the material and human resources necessary to perform its activity, or its income originates from: (i) passive income that represents at least 50% of the entity profits for the fiscal year, or (ii) income of any kind that directly or indirectly generates deductible expenses for related parties resident in Argentina.  In these last cases, only the results derived from this type of income shall be taxed in accordance with the provisions of this subsection.  
3) That the income or profits mentioned in section 2) above, are taxed at an effective rate that falls below 75% of the corporate tax rate at which they would have been taxed in Argentina. It is presumed that this condition is met if the foreign entity is constituted, domiciled, or located in a non-cooperative, low or no-tax jurisdiction or country.