Alerta Legal 002-2016 Chile: El servicio de Impuestos Internos (SII) anuncia multas de hasta 300% en Precios de Transferencia.

1. Antecedentes:


El 12 de mayo de 2016, el SII publicó la circular N° 31 continuando así con el Plan de Gestión del Cumplimiento Tributario 2016 y en línea con la Organización para la Cooperación y el Desarrollo Económico (OCDE) y el plan de acción BEPS (Erosión de la base imponible y el traslado de beneficios) en la cual informa y detalla las sanciones aplicables en el tema de Precios de Transferencia conforme a lo dispuesto en el numeral 6 del artículo 41 E de la Ley de Impuesto a la Renta.

2. Numeral 6 del Articulo 41 E de la Ley de Impuesto a la Renta


El numeral 6 del artículo 41 E de la Ley de Impuesto a la Renta, dispone que la no presentación de la declaración Jurada sobre Precio de Transferencia Nº1907 (DJ 1907), o su presentación errónea, incompleta o extemporánea, se sancionará con una multa 10 a 50 unidades tributarias anuales (US$ 7,800 a US$ 39,000 respectivamente). Con todo, dicha multa no podrá exceder del límite mayor entre el equivalente al 15% del capital propio del contribuyente determinado conforme al artículo 41 de la Ley sobre Impuesto a la Renta o el 5% de su capital efectivo. Si la declaración presentada conforme a este número fuere maliciosamente falsa, se sancionará conforme a lo dispuesto por el inciso primero, del número 4°, del artículo 97, del Código Tributario, esto es, multa que asciende a 50% – 300%, del valor del tributo eludido, y con presidio menor en sus grados medio a máximo, 541 días a 5 años.

3. Precisiones de terminologías


Para los fines de la aplicación de la circular Nº 31, el SII ha desarrollado algunos conceptos y especificado ciertos términos, según lo siguiente:


1. Capital propio:

El artículo 41 de la Ley sobre Impuesto a la Renta define el capital propio como la diferencia entre el activo y el pasivo exigible a la fecha de inicio del ejercicio
comercial, debiendo rebajarse previamente los valores intangibles, nominales, transitorios y de orden y otros determinados por la Dirección Nacional, que no representen inversiones efectivas. Corresponde aplicar esta definición para los fines de la aplicación de la referida sanción.

2. Capital efectivo:

De acuerdo con el concepto dado por la Ley sobre Impuesto a la Renta en el número 5 de su artículo 2°, se entenderá por capital efectivo la totalidad del activo, con exclusión de aquellos valores que no representan inversiones efectivas, tales como valores intangibles, nominales, transitorios y de orden.

3. Límite de la multa:

En principio, la sanción corresponderá a una multa que podrá ser de 10 a 50 Unidades Tributarias Anuales. No obstante aquello, la norma dispone expresamente que cuando ambos tipos de capital sean determinables, el límite de la sanción que se deberá considerar será el monto que resulte mayor de la comparación entre el 15% del capital propio y el 5% del capital efectivo. En caso que por diferentes circunstancias no sea posible determinar el capital propio o su monto resulte negativo, para efectos del límite que contempla la norma se considerará sólo el capital efectivo.


Ahora bien, en caso que no sea posible determinar los montos de los capitales indicados anteriormente, la multa a aplicar será la mínima de las señaladas, es decir, 10 UTA.

4. Conductas Sancionadas:

Declaración jurada no presentada

Las multas se aplicarán dependiendo del número de operaciones que debieron ser informadas y de la oportunidad en que se presente la declaración, fluctuando por lo tanto, entre los tramos que se indican:

De manera previa a la notificación de estas multas, el Servicio enviará avisos simples a los contribuyentes que de acuerdo a sus bases de datos se encuentran obligados a presentar la declaración jurada, y no lo hayan hecho dentro del plazo legal, para que en el plazo de un mes, contado desde el envío de dicho aviso, la presenten efectivamente, en cuyo caso se podrán aplicar las sanciones que se indican en la letra siguiente.


Declaración jurada presentada fuera del plazo legal (extemporánea)


Las multas se aplicarán dependiendo del número de operaciones que debieron ser informadas en total al término del ejercicio respectivo, fluctuando por lo tanto, entre los tramos que se indican:

Se debe tener presente que en el caso que el contribuyente haya solicitado prórroga para la presentación de la declaración jurada y ésta haya sido otorgada por la Dirección Regional respectiva o la Dirección de Grandes Contribuyentes, la presentación de la declaración durante el periodo de vigencia de dicha prórroga no está afecta a la multa señalada precedentemente.

Declaración jurada presentada en forma incompleta o errónea.

La presentación de la declaración jurada en forma incompleta o errónea, será sancionada teniendo en consideración la circunstancia de si se ha presentado o no la correspondiente declaración rectificatoria dentro del plazo original o el prorrogado, según corresponda. En el caso de haberse presentado dicha declaración rectificatoria, la sanción se aplicará de acuerdo a la oportunidad en que se efectuó la corrección por parte del contribuyente, de acuerdo con la siguiente tabla:

Si la declaración rectificatoria se presenta dentro del plazo original, es decir, el último día hábil del mes de junio de cada año o dentro del prorrogado hasta el último día hábil de septiembre de cada año, no se aplicará sanción.

Declaración jurada presentada en forma maliciosamente falsa

Si la declaración presentada fuere maliciosamente falsa, se sancionará al contribuyente con multa del 50% al 300% del valor del tributo eludido y con presidio menor en sus grados medio a máximo, conforme a lo dispuesto por el inciso 1°, del numeral 4°, del artículo 97 del Código Tributario.

5. Procedimiento de aplicación de las sanciones.

La norma dispone que la aplicación de la multa en el caso de la no presentación de la declaración jurada o si ésta se presenta en forma extemporánea, incompleta o errónea, se someterá al procedimiento establecido en el artículo 165 N°1 del Código Tributario. Esto implica que serán aplicadas sin otro trámite que el de ser giradas por el Servicio o solucionadas por el contribuyente al momento de presentar la declaración o efectuar el pago, pudiendo ser reclamado el giro de la multa ante el Tribunal Tributario y Aduanero correspondiente, en el plazo de 15 días hábiles contados desde la notificación
del giro, de acuerdo a lo dispuesto en el N°4 del artículo 165 del Código Tributario.

En caso que la presentación de la Declaración Jurada sobre Precios de Transferencia fuere maliciosamente falsa, se sancionará al responsable conforme lo dispuesto en el inciso primero del N°4 del artículo 97 del Código Tributario. Sobre el particular, se debe tener presente que de conformidad a lo dispuesto por el inciso tercero del artículo 162 del Código Tributario, si la infracción pudiere ser sancionada con multa y pena privativa de libertad, el Director podrá, discrecionalmente, interponer la respectiva querella o denuncia o enviar los antecedentes al Director Regional competente para que se persiga la aplicación de la multa correspondiente a través del procedimiento establecido en el artículo 161 del mismo cuerpo legal.

6. Conclusiones y recomendaciones:

6.1. La administración tributaria chilena impondrá multas desde 50% hasta el 300% del impuesto eludido, e incluso presidio menor en sus grados medio a máximo en casos de declaraciones “maliciosamente falsas” de precios de transferencia.

6.2. Adicionalmente, el Servicio de Impuestos Internos (SII) contempla multas por la no presentación de declaraciones, cuando contengan información incompleta o errónea, o si la presentación se realiza fuera de plazo. Tratándose de declaraciones no presentadas, se contemplan multas que van de USD 7,800 a USD 39,090 aproximadamente, dependiendo de la cantidad de operaciones que debieron ser informadas y la oportunidad en que se presente el documento. Para los cumplimientos fuera de plazo las multas van de USD 3,900 a USD 31,270. Mientras, las declaraciones incompletas o erróneas se sancionarán entre USD 110 y USD 31,270.

6.3. Las instrucciones contenidas en la circular N° 31 hacen indicar que la Administración Tributaria comenzará con fiscalizaciones más exhaustivas y
ante ello es importante que los contribuyentes tomen con mayor atención los temas referidos a Precios de Transferencia. Por lo que recomendamos tomar todas las previsiones del caso para la presentación de la DJ 1907 y su correspondiente Estudio de Precios de Transferencia.

Atentamente,

RODRIGO SERRANO

Gerente TP Consulting Chile

e-mail: rserrano@tpconsulting-group.com

Tel: (56-2) 2944-5015

Alonso de Córdova 5870, Oficina 1605, Las Condes, CHILE.

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