La Comisión Arbitral estableció que las retenciones de Ingresos Brutos no pueden basarse en presunciones

RESOLUCION GENERAL (CA) N° 3/2010 - BO 23/04/2010

La Comisión Arbitral del Convenio Multilateral estableció que las jurisdicciones no podrán incluir a sujetos pasibles de recaudación basándose en presunciones.

Esta nueva medida surgió como consecuencia de los desmesurados regímenes de retención, percepción y recaudación bancaria que establecieron las distintas jurisdicciones en los últimos años, y fue disparada principalmente por el conflicto que se generó a partir de las sumas que la Agencia de Recaudación de Pcia. de Buenos Aires (ARBA) retiene de las cuentas bancarias de todo el país.

A través de la presente resolución general se sustituye el texto de su similar N° 61/95, que oportunamente estableció las pautas que deben respetar los regímenes de retención y percepción.

En primer lugar, destacamos que la nueva norma abarca a todos los regímenes de recaudación (incluso las retenciones bancarias).

Por otro lado, se mantiene la redacción anterior en cuanto a que "podrán resultar sujetos pasibles de retención o percepción aquellos contribuyentes que realicen actividades con sustento territorial en la jurisdicción que establezca el régimen respectivo".

Sin embargo, la nueva resolución aclara que el sustento territorial y el carácter de sujeto pasible no se podrá fundar en presunciones.

Si bien presente resolución no define qué se entiende por "presunciones" a efectos de la aplicación del presente régimen, consideramos aplicable la definición aceptada por la doctrina mayoritaria en Derecho Tributario, que considera que en las presunciones, "a partir de un hecho conocido, se infiere un hecho desconocido cuya existencia es muy probable".

Finalmente, destacamos que la presente norma tiene vigencia a partir del próximo 1° de mayo.

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