El concepto de “devengado” en el Impuesto a las Ganancias
Date | 29 July 2011 |
Author | Walter C. Keiniger |
Published date | 29 July 2011 |
Law Firm | Marval O'Farrell Mairal |
La controversia se suscitó a raíz de la impugnación por parte del Fisco Nacional de la deducción de los gastos incurridos por el contribuyente como consecuencia de ciertos contratos de exclusividad suscriptos con sus clientes.
La Ley del Impuesto a las Ganancias prevé la aplicación del criterio de imputación de lo devengado cuando se trata de ganancias de tercera categoría (rentas de empresa). La discusión versó sobre el modo de aplicación de ese criterio en el caso concreto.
El contribuyente había deducido en el ejercicio correspondiente a la celebración del contrato los montos abonados a sus clientes como contraprestación de la aludida exclusividad. El Fisco, en cambio, consideró que la imputación debía hacerse en forma proporcional al servicio realmente prestado en cada período fiscal, lo que fue apeldo por el contribuyente.
El Tribunal Fiscal de la Nación adhirió a la posición del Fisco y consideró que el concepto de “devengado” implica que los ingresos y...
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