Jurisprudencia de la C.S.J.N.: Impuesto a las ganancias. Ganancias de fuente extranjera. Establecimiento Estable.

«Maltería Pampa S.A. (TF 27.000-1) c/ DGI”, CSJN, 24/02/15.

SUMARIO.- Impuesto a las ganancias. Ganancias de fuente extranjera. Establecimiento Estable.

En el caso, el Máximo Tribunal recordó que la ley del impuesto a las ganancias distingue a las sociedades por acciones de aquellos otros entes a los que denomina «establecimientos estables». Definió a estos últimos, y por interpretación de los arts. 18, 69, 119, 128 y 133 de la ley 20.628, consideró que en razón de ellas, los accionistas residentes en el país han de imputar en sus respectivas declaraciones los resultados positivos obtenidos por sociedades por acciones residentes fuera de él y no ubicadas en países de baja o nula tributación, únicamente cuando existan dividendos y ellos les hayan sido puestos a su disposición; circunstancia que no se daba en el caso, por lo que correspondía revocar parcialmente la sentencia de la anterior instancia, teniendo en cuenta lo manifestado en el considerando 12.

Sumario realizado por la Dra. Carolina Petraglia

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31 comentarios de “Jurisprudencia de la C.S.J.N.: Impuesto a las ganancias. Ganancias de fuente extranjera. Establecimiento Estable.

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