El intercambio de información aduanera no es suficiente para cuestionar el valor de los bienes
Author | Juan Pablo Rothschild,Daiana Ayelen Salvador |
Published date | 30 June 2022 |
Date | 30 June 2022 |
Law Firm | Marval O'Farrell Mairal |
Se trata del fallo PIONEER ARGENTINA SRL - TF 34802-A c/ DGA s/RECURSO DIRECTO DE ORGANISMO EXTERNO (18167/2021).
En el caso, la firma Pioneer Argentina SRL documentó una exportación con destino a Brasil, a la firma Du Pont do Brasil, según le fue indicado por el comprobado Pioneer Overseas Corporation, a nombre de quien emitió la factura y de parte de quien recibió las divisas. Esta última, había convenido con la empresa brasilera una venta sucesiva por un precio superior al de la venta inicial.
Pioneer Argentina S.R.L y Pioneer Overseas Corporation de los Estados Unidos se encontraban vinculadas, lo cual fue declarado oportunamente al momento de confeccionar la “Declaración de los elementos relativos al valor de exportación”. Ante tal situación, el servicio aduanero contaba con facultades para investigar una posible diferencia entre lo declarado y verificado. En ese sentido, el organismo aduanero a partir del sistema INDIRA (Sistema de Intercambio de Información de los Registros Aduaneros) constató que la mercadería vendida por Pioneer Argentina S.R.L. a la firma Pioneer Overseas Corporation había ingresado al mercado brasilero –en una venta sucesiva a Du Pont do Brasil– por un valor FOB superior al que se había exportado desde la República Argentina.
El Fisco señala que no es razonable que se...
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