Implicancias de la introducción de Precios de Transferencia a la nueva Ley de Fortalecimiento de las Finanzas Públicas sobre la Renta y el IVA

Los grupos empresariales multinacionales deberán contar con la documentación de precios de transferencia que indique el cumplimiento del principio de plena competencia a fin de no realizar ajustes a la Declaración de Impuesto a la Renta / IVA por Precios de Transferencia.

En línea con la transparencia fiscal a la que el país apunta como parte de su intento por ingresar a la OCDE, el Ministerio de Hacienda introdujo en la nueva Ley de Fortalecimiento de las Finanzas Públicas el “Principio de Plena Competencia”; término que se refiere a los “Precios de Transferencia”. Dicho principio establece que los precios pactados en las operaciones entre el contribuyente con partes vinculadas, domiciliadas y no domiciliadas deben pactarse como si se tratasen de terceros independientes.

En ese sentido, a lo largo del documento se introducen condiciones para las transacciones entre partes vinculadas, además de las implicancias sobre otras declaraciones: impuesto a la renta, impuesto al valor agregado, asimismo en los impuestos a las ganancias de capital, deducción de gastos, entre otros.

Impuesto a la Renta

La adición del artículo 81 bis en el nuevo capítulo XXXI y la vigésimo primera disposición complementaria transitoria, reiteran que aquellas compañías que estén calificadas como: Grandes Contribuyentes Nacionales, Grandes Empresas Territoriales y aquellas empresas que operen bajo el Régimen de Zona Franca están obligadas a realizar las Declaraciones Anuales de Precios de Transferencia.

Asimismo, la Resolución de Hacienda N°DGT-R-44-2016 y la segunda disposición complementaria transitoria de la Resolución de Hacienda N°DGT-R-28-2017, señalan que los contribuyentes obligados deberán conservar la documentación de precios de transferencia para ponerla en disposición de Administración Tributaria para cuando así lo solicite y establece que en junio de cada año se debe contar con la información del periodo inmediatamente anterior.

De esto último, al día de hoy los contribuyentes obligados deberían contar con la documentación de Precios de Transferencia del periodo fiscal 2017 hacía atrás y en junio 2019, deberían tener lista la documentación del periodo fiscal 2018.

Por otro lado, se faculta a la Administración Tributaria a comprobar el principio de plena competencia en las operaciones con partes vinculadas y a realizar los ajustes de valoración cuando producto de los precios pactados resulte una menor tributación en el país. Cabe destacar, que podrán suscribirse acuerdos previos sobre valoración de precios de transferencia, sean estos unilaterales, bilaterales o multilaterales.

Impuesto al Valor Agregado

Como se indica en el párrafo anterior, la Administración Tributaria ajustaría la base imponible del impuesto sobre la renta en el caso de encontrar que existe perjuicio fiscal en la compañía que analiza, respecto de las transacciones que realice con otra parte vinculada.

De igual forma con la publicación de la Ley N° 9635 es obligatorio considerar el análisis de las transacciones sometidas a estudio de precios de transferencia, en caso de que alguna de ellas no cumpla con el principio de plena competencia y por lo tanto, tratándose de venta de bienes o de servicios, haya que realizar un ajuste y aumentar la base imponible del impuesto al valor agregado en caso de que se identifique que hubo perjuicio en contra de los intereses del Fisco:

“En las operaciones entre partes vinculadas, el precio neto de venta debe ajustarse al valor normal de mercado que pactarían partes independientes, siempre que se produzca un perjuicio fiscal.”

A modo de conclusión, es importante que los contribuyentes consideren ambos impuestos en las situaciones y análisis que realicen de sus transacciones con vinculadas y cuenten con la documentación sustentatoria de Precios de Transferencia previo a las Declaraciones del Impuesto y el Valor Agregado a fin de no realizar ajustes en ambas originadas por precios de transferencia.

Alertas de precios de transferencia

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