Ingresos Brutos: empresas pagarán sólo en provincias donde tengan actividad

Las empresas que tienen poca actividad en una provincia ya no deberán sufrir percepciones del Impuesto sobre los Ingresos Brutos en esa jurisdicción, algo que llevaba a que se acumularan saldos a favor en el tributo imposibles de recuperar, por lo que eran un verdadero impuesto sin base y por montos muy importantes en muchos casos.

El fin de las percepciones sin base se producirá por una decisión de la Comisión Arbitral, el organismo que tiene autoridad sobre el funcionamiento del Convenio Multilateral, por el que se distribuye ese gravamen entre los distritos del país en los que tenga actividad una empresa.

Muchas compañías sufrían percepciones del Impuesto sobre los Ingresos Brutos por parte de varias provincias en las que tenían poca actividad y se les generaba saldo a favor en el gravamen.

La Comisión Arbitral estableció que es necesario, para poder percibir el Impuesto sobre los Ingresos Brutos, que efectivamente se demuestre actividad en la jurisdicción, situación que se da cuando hay coeficiente en el Régimen General del Convenio Multilateral.

Si el coeficiente de la jurisdicción es inferior a 0,0050 no se pueden aplicar percepciones y de esa manera se evita la generación permanente de saldos a favor.

En los fundamentos, la Resolución General 24/2016 de la Comisión Arbitral, del 16 de noviembre pasado, dice que es responsabilidad de este Organismo procurar que los regímenes de recaudación del Impuesto sobre los Ingresos Brutos se ajusten a parámetros razonables, que no vulneren el objetivo primordial de evitar la doble o múltiple imposición. Agrega que al respecto se ha considerado conveniente realizar ajustes asociados a los requisitos aplicables al sujeto pasible de percepción.

  • En su único artículo, la RG dispone que podrán resultar sujetos pasibles de percepción aquellos contribuyentes que cumplan con alguna de las siguientes situaciones:
  • Inscriptos en el régimen del Convenio Multilateral e incorporados a la jurisdicción respectiva.
  • Inscriptos en el régimen del Convenio Multilateral, que sin estar inscriptos en la jurisdicción respectiva, evidencien su calidad de tal por las declaraciones juradas presentadas.
  • No mencionados en los casos anteriores, excepto que se trate de lo que sigue:
  • Contribuyente local inscripto exclusivamente en una jurisdicción distinta a la que pretende aplicar el régimen de percepción.
  • Contribuyente de Convenio Multilateral que no tenga incorporada la jurisdicción por la cual se pretende aplicar el régimen de percepción.
  • Contribuyente que distribuya la mayor parte de sus ingresos mediante el Régimen General del Convenio Multilateral, cuando el coeficiente del sujeto pasible de percepción atribuible a la jurisdicción sea inferior a 0,0050. A dichos fines, el sujeto pasible de percepción deberá exhibir copia de la última declaración jurada exigible (Formulario CM05).

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