“Extravió” sus facturas, no pudo demostrar ante AFIP sus compras y ahora pagará más Ganancias

Si bien el contribuyente declaró que perdió la documentación respaldatoria, el Tribunal Fiscal de la Nación decidió avalar la postura del organismo de recaudación. ¿Cuáles fueron los argumentos de los vocales?. Las claves del caso y la opinión de los expertos

No caben dudas de que los comprobantes de respaldo de las diversas transacciones de un contribuyente son fundamentales al momento de determinar cuánto se pagará de impuestos.

Ya sea que se trate de facturas o tickets de compras y ventas, remitos, recibos, resúmenes bancarios o de tarjetas de crédito -entre otros tantos-, todos son elementos clave para fijar la base imponible tributaria.

Esto es así debido a que de ellas surgirán los créditos y los débitos -así como los ingresos y gastos- que determinarán cuánto deberá ingresarse a la Administración Federal de Ingresos Públicos (AFIP).

Más aún si se tiene en cuenta que la base determinativa de los gravámenes en la Argentina se sustenta en la “autodeterminación”; es decir, es el contribuyente quién, con los documentos que posee, calcula el importe que debe pagar al fisco.

Asimismo, en caso de recibir la visita de algún inspector de la AFIP, dichos comprobantes resultan sumamente importantes debido a que permitirán verificar que las declaraciones juradas impositivas fueron confeccionadas correctamente.

Ahora bien, ¿qué sucede cuando, por alguna razón, se pierden las facturas de compras realizadas en algún período?.

Esto fue lo que sucedió en el marco de una reciente causa donde el Tribunal Fiscal de la Nación (TFN) determinó que el contribuyente debía abonar más Impuesto a las Ganancias por no contar con los comprobantes correspondientes, pese a que adujo que fueron extraviados.

Los expertos consultados por iProfesional.com destacaron que el fallo deja la puerta abierta para la utilización de presunciones por parte del contribuyente para determinar sus costos, siempre que se den algunas situaciones.

Además, sugirieron algunos tips a tener en cuenta si se extravía algún tipo de documentación contable para recomponer la situación impositiva.

El caso por dentro
Todo comenzó cuando la AFIP, tras una inspección, determinó de oficio una deuda a Raquel Botta en el Impuesto a las Ganancias por el período fiscal 2002 más sus respectivos intereses resarcitorios.

Aunque la contribuyente había advertido a los inspectores actuantes que los comprobantes de ciertas operaciones de compras habían sido entregados a un estudio contable quién “extravió la documentación respaldatoria de -esos- movimientos”, los agentes hicieron caso omiso del asunto.

Por esta razón, Botta -que se dedicaba a la venta de cueros- decidió presentarse ante el TFN, argumentando que los elementos utilizados para la determinación, si bien eran concretos, “no se condicen con la realidad”.

Entendía que, a los cálculos realizados por los inspectores, era necesario agregar compras de mercaderías de reventa realizadas durante el período en cuestión.

Esto era así, según la demandante, porque “de la simple observación de las existencias iniciales, compras y ventas de cueros pueden advertirse diferencias que no permiten cerrar la ecuación necesaria para determinar la materia imponible”.

En este sentido, adujo que el fisco determinó que existieron ventas por 19.426 cueros, mientras que las compras en el período ascendieron a 13.445 unidades.

Así, teniendo en cuenta que el inventario inicial era de 122 productos, la contribuyente entendía que debieron existir 5.859 unidades que “para haber podido ser vendidas, debieron antes ser compradas”.

Sin embargo, para el TFN la razón la tenía la AFIP y no la contribuyente.

Para arribar a esta conclusión, los vocales sostuvieron, en primer lugar, que “la apelante tan sólo se limita a alegar una supuesta pérdida de la documentación por parte del estudio contable” pero que, dicha circunstancia no fue “probada en ningún momento”.

Respecto del mecanismo utilizado por Botta para arribar a su conclusión, desde el TFN destacaron que “no se presenta como adecuado ni eficaz para la demostración de los referidos extremos”.

Los vocales entendieron que “para arribar a tal conclusión se le presenta como necesario traducir previamente los mencionados montos en unidades de producto”, pero, no obstante, “no obra prueba alguna a lo largo de las presentes actuaciones” de cómo fueron realizadas dichas operaciones.

En consecuencia, el TFN concluyó que la “improcedencia (del cálculo) deviene manifiesta”, debido a que no fue probado el hecho de que la diferencia de unidades entre las compras y ventas determinadas por AFIP fueron compras, tal como pretendía la contribuyente.

Voces
Juan Pablo Scalone, socio del estudio Enrique Scalone & Asociados, destacó que lo más importante del caso fue que “no cierra la puerta a la estimación de costos, de verificarse circunstancias excepcionales que la justifiquen”.

Así, para el experto, esas circunstancias deberían ser, por un lado, “circunstancias fehacientemente probadas de las que surja la necesidad de recurrir a la estimación” y, por el otro, la “elección del método más adecuado y razonable a los fines de realizar la estimación”.

Por su parte, el consultor tributario Iván Sasovsky sostuvo que “el razonamiento del Tribunal es muy lógico y atinado, ya que responde a la lectura armónica de las normas y al sentido común, dado que considera válido que si no se cuenta con la documentación respaldatoria, el fisco debe utilizar todas las alternativas que le permitan cumplir con su función“.

De esta manera, para el especialista “está más que justificado el uso del método presuntivo”.

En tanto, para la abogada especialista en impuestos, Karina Larrañaga, “se habría utilizado un sistema mixto” al momento de determinar cuáles fueron los ingresos y egresos de la firma.

Esto es así “porque gran parte de la información se obtuvo de terceros y en definitiva el fisco reconstruyó la materia imponible de esa forma (con lo cual quedan fuera del circuito las compras y ventas realizadas sin soporte documental) y no sobre la documentación, registros, libros y demás papeles contables del contribuyente”, indicó.

Y agregó: “Sinceramente me parece que existe un error o una interpretación `novedosa´ del Tribunal sobre el concepto de `base cierta´“.

El uso de los métodos presuntivos
En otro orden de ideas, los especialistas pusieron de manifiesto cuándo es correcto el uso de las presunciones por parte de la AFIP.

Al respecto, Sasovsky sostuvo que “no se debe perder de vista que las presunciones son instrumentos a partir de los cuales, basándose en hechos reales, se puede reconstruir el status y el quantum de la obligación de un contribuyente a un determinado momento”.

“En el caso particular, el fisco no hizo otra cosa que basarse en datos y documentación real que claramente puede utilizarse como elemento probatorio en sí mismo, y como disparador del instituto de las presunciones”, señaló.

En este contexto, Larrañaga sostuvo que “el contribuyente no puede invocar la existencia de sistemas indiciarios de determinación a su favor cuando extravió los libros, no acreditó tal extremo, y rechaza la estimación fiscal solo en la parte que le interesa, es decir, en tanto y en cuanto no consideró la deducción por costo de ventas”.

Y agregó: “Todo el sistema contencioso se sustenta en la prueba ofrecida y producida y en el fallo parecería que la prueba ofrecida y producida por el contribuyente fue poca y contradictoria según sus intereses”.

Asimismo, la especialista indicó que “pese a que el sistema de estimación indiciaria en principio, parecería solo jugar a favor del fisco para reconstruir la materia imponible, el contribuyente podría utilizarlo a su favor e invocarlo, en tanto y en cuanto, justifique esta situación”.

Para ello, era necesario que acreditara “que efectivamente perdió los elementos de prueba por causas ajenas e inculpables y, además, ofrezca elementos contundentes para reconstruir la materia imponible que no se contradigan entre sí”.

En tanto, Sasovsky indicó que “los principales elementos utilizados por el organismo recaudador fueron las declaraciones juradas del Impuesto al Valor Agregado, siendo las mismas confeccionadas y aportadas por el propio contribuyente, dado su carácter de autodeterminativas“.

“En efecto, y al comprender que nadie puede alegar su propia torpeza, resulta ridículo pretender que el fisco no tome dichos elementos como sustento presuntivo y que la reconstrucción de los hechos se haga sobre elementos probatorios diferentes”, razonó el especialista.

Cómo actuar ante la pérdida de documentación
Respecto de cuáles son los pasos que se deben realizar para justificar la pérdida de documentación, los especialistas dieron algunos tips para no tener un dolor de cabeza en el futuro.

En este orden de ideas, Larrañaga señaló que “si el contribuyente alega que `extravió el soporte documental impositivo, debe probarlo de alguna forma´“.

De esta manera, para la experta, “no resulta válida la mera invocación de esta circunstancia para omitir el cumplimiento de uno de los deberes formales sobre los que se asienta todo el sistema de verificación y fiscalización y después objetar el ajuste”, tal como sucedió en la causa.

Por su parte, Mario Buedo, socio del estudio Montero & Asociados, explicó que, si bien “llevará tiempo”, no es imposible recomponer toda la información que pudiera haberse extraviado.

En este escenario, el experto recomendó “solicitar a los clientes copias certificadas de los duplicados de las facturas emitidas que están en su poder y a los proveedores copias de las facturas originales recibidas” de modo de obtener las ventas y compras realizadas.

Para el supuesto que el sujeto que extravió la documentación estuviera obligado a emitir facturas electrónicas, la información deberá tomarla de los registros online que se mantienen con la AFIP.

Respecto de todo lo concerniente a la parte impositiva, especificó que “se puede reconstruir las declaraciones de Ganancias, IVA y cualquier otra a través del SIAP“, siempre que lo que no se haya siniestrado fueran los ordenadores.

“Incluso, en el caso de las retenciones y percepciones, puede recomponerse la situación a través del sistema `Mis retenciones´, al que se accede desde el portal de la AFIP con clave fiscal”, sostuvo el experto.

Si lo que se extravió fueron los libros, Buedo sugirió: “Primero, habría que hacer una denuncia policial, ya que son libros rubricados, y luego iniciar el trámite de rúbrica de un nuevo juego de libros obligatorios”.

Otro de los documentos que pueden obtenerse -siempre que se trate de una sociedad anónima-, son copias de “los estados contables y actas de asamblea y directorio presentadas “ solicitando el legajo que obra en la Inspección General de Justicia.

Por último, el especialista recomendó “pedir toda la información que posean los bancos, ya que, por ejemplo, a través de los movimientos bancarios, se pueden reconstruir circuitos de pagos de facturas y de cobro de servicios o productos vendidos”.

Fuente: iprofesional.com

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