2. X Corp is a resident of State A. X Corp is the 100 % shareholder of Y Corp, a resident of State B. Y Corp holds 100% of the shares in Z Corp, a resident of State C. Z Corp distributes dividends to Y Corp. The tax authorities of State C is of the opinion that Y Corp is not the real beneficial owner of the dividends. Y Corp is interposed to benefit from the favorable tax treaty between B and C. The tax authorities of State C consider the whole structure to be an abuse and allocate the dividends to X Corp, the "real beneficial owner". Do you agree with the decision of the tax authorities of State C, why?