ECONOMÍA

Reforma Tributaria: ¿Ya comenzó? ¿Qué de nuevo nos trae?

Fuente: The Balance

El Artículo 104º de la Constitución Política del Perú indica que el Congreso puede delegar al Poder Ejecutivo la facultad de legislar, mediante decretos legislativos, sobre alguna o algunas materias en específico.

En ese sentido, el pasado 19 de julio se publicó la Ley N° 30823 a través de la cual se delegó al ejecutivo la facultad de legislar por el plazo de 60 días calendario en materia tributaria y financiera.

De acuerdo con el contenido de esta norma legal, se establecieron los alcances y limitaciones respecto de los decretos que pueden ser emitidos por el ejecutivo. A continuación, veremos algunos de los temas que despiertan el mayor interés y que podrían ser materia de los próximos ajustes en materia fiscal. ¡Estemos prevenidos!

  1. Modificaciones a Impuestos directos (Impuesto a la Renta)

Por un lado, tenemos como novedad la esperada regulación del concepto de “devengado” para el reconocimiento de ingresos corporativos. Durante muchos años se pensó que este concepto estaba más vinculado a una doctrina contable que a una tributaria (jurídicamente hablando). Así, las empresas, en términos sencillos, pagarían el impuesto cuando se trasladaban los riesgos y beneficios de la operación a sus clientes y no necesariamente cuando las facturas emitidas fueran cobradas.

Sin embargo, con la llegada de las nuevas normas internacionales de información financiera, la aplicación del “devengado” se ha vuelto más compleja para efectos tributarios. Situación que genera incertidumbres y riesgos asumidos por las empresas ante las diferencias entre estas normas y las reglas contenidas en la Ley.

Una regulación expresa del término del “devengo” podría apoyar a solucionar la zona gris existente y dar mayor predictibilidad a las empresas de sus riesgos tributarios. Sin embargo, las modificaciones suelen ser para el futuro. ¿Qué pasará por los ejercicios ya vencidos? Veremos que nos trae esta nueva definición.

Por otro lado, existe la tendencia a seguir empleando a las personas naturales como un vehículo para enfrentar la informalidad. Inició el año pasado con la posibilidad de reducir sus impuestos solicitando recibos de honorarios a sectores con alto nivel de evasión (servicios profesional independientes como dentistas, médicos, entre otros). Se plantea ahora en la norma bajo comentario concederle mayores posibilidades de reducir el pago de sus impuestos mediante la obtención de comprobantes de pago de terceros de diversas clases.

Veremos los alcances que trae esta situación y que tan atractiva resulta para las personas naturales. Por ahora, conviene comenzar a recopilar y conservar los documentos asociados a nuestros gastos y desembolsos. Algunos de éstos podrían servir para recuperar o bajar nuestro impacto fiscal dentro de poco.

Posiblemente podríamos llegar a un sistema determinativo similar al que tienen las personas naturales en otras latitudes (i.e. Estados Unidos). Esperemos que estas nuevas reglas no hagan tan compleja la determinación de los impuestos de personas naturales como sucede ahora con las personas jurídicas del régimen general.

  1. Modificaciones a Impuestos indirectos (ISC, IGV)

SUNAT tomó conciencia de la popularidad de las casas de apuestas en línea –en especial durante el mundial pasado- y ha decidido comenzar a regularlas.  Hasta la fecha, la regulación sobre estas modalidades de apuestas era muy escueta -sino inexistente- generando una oportunidad para ampliar la base tributaria por esta situación (principalmente, Impuesto Selectivo al Consumo-ISC).

Existirá un reto entonces para su regulación respecto de las casas de apuestas internacionales que tiene su centro de negocios fuera del país tal y como sucede con otras aplicaciones conocidas de taxis.

Por otra parte, se estima seguir generando candados para la libre disposición de los fondos no utilizados en las cuentas de “detracciones”.

Actualmente, por “inconsistencias” derivadas de simples diferencias en el monto de ingresos declarados (devengados) con las ventas facturadas, se le corta la posibilidad al contribuyente de recuperar estos fondos y utilizarlos como capital de trabajo. En el mejor de los casos, debe iniciar un procedimiento tributario que demora varios días, cortando la posibilidad de obtener una caja más a corto plazo.

Sin perjuicio de lo anterior, ésta ha resultado una vía eficiente para incrementar la recaudación para los sectores más informales o con mayor índice de evasión tributaria.

  1. Otros temas tributarios

Se persigue ampliar el alcance de la aplicación de la norma anti-elusiva regulada por la Norma XVI del Título Preliminar del Código. Ello permitirá hacer más difícil la realización de planificaciones tributarias agresivas de parte de los contribuyentes estableciendo parámetros nuevos para la aplicación de sanciones y generar mayor responsabilidad en representantes legales.

La actualización de normas anti-elusivas se realiza con el objetivo de incorporar al Perú como país miembro de la Organización para la Cooperación y el Desarrollo Económico (OCDE). La mayoría de los países miembros tienen incorporadas en su legislación una Cláusula General anti-elusiva como parte de un sistema jurídico tributario competitivo.

Asimismo, se fortalecerá el control tributario vía medios electrónicos masificando el uso de comprobantes de pago electrónicos, así como de libros y registros electrónicos. Se establecerá mayor control a los operadores de servicios electrónicos y se modificará el régimen de infracciones y sanciones.

Finalmente, se plantean realizar ajustes a las normas que regulan el secreto bancario para controlar las operaciones y rentas no declaradas por los contribuyentes.

Como se aprecia, se vienen cambios masivos al sistema tributario peruano, por lo que conviene estar informados para evitar sorpresas y riesgos inadvertidos.

Luciano Gamarra
Abogado por la UPC , especializado en Tributación, con maestría en Finanzas y Derecho Corporativo en ESAN. Profesor de Derecho Tributario. Empresario y asesor de emprendimientos por elección. Apasionado por ayudar a las empresas y personas a crecer y generar eficiencias. Un hombre agradecido que busca concretizar sus sueños cada día.
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