Novedosa interpretación de la AFIP sobre la aplicación del Impuesto sobre los Créditos y Débitos en Cuentas Bancarias del exterior
Published date | 15 August 2007 |
Author | Gabriel Gotlib,Juan Pablo Rothschild |
Date | 15 August 2007 |
Law Firm | Marval O'Farrell Mairal |
En la Resolución Nº 19/2007[1], la Administración Federal de Ingresos Públicos (AFIP) analizó una consulta vinculante efectuada por un contribuyente local sobre la aplicación del Impuesto sobre los Créditos y Débitos en Cuentas Bancarias (ICD) a movimientos operados entre cuentas bancarias radicadas en el exterior originados en (i) depósitos efectuados por el accionista mayoritario para integrar un aumento de capital y (ii) las posteriores salidas efectuadas para cancelar un préstamo financiero otorgado en el exterior.
En primer lugar, la AFIP analizó si los movimientos bancarios ocurridos en el exterior constituían un sistema organizado de pagos creado para reemplazar el uso de cuentas bancarias en entidades financieras, supuesto que está alcanzado por el ICD. La AFIP determinó que el aporte de capital y la cancelación de un préstamo no eran actividades habituales de la compañía y, por lo tanto, no podía interpretarse que el contribuyente hubiera ideado un sistema organizado de pagos para reemplazar el uso de cuentas bancarias.
En segundo lugar, la AFIP sostuvo que el ICD...
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