«Negri, Fernando Horacio c/ EN – AFIP DGI» (15/7/2014) – CSJN –

SUMARIO. En fecha 15/7/2014 la Corte Suprema de Justicia de la Nación revocó la sentencia de la Sala I de la Cámara Nacional de Apelaciones en lo Contencioso Administrativo Federal, por la cual se había confirmado la denegatoria de la repetición intentada por el actor de la suma de $ 104.719,19 que le fuera retenida en concepto de impuesto a las ganancias al percibir la liquidación correspondiente su retiro voluntario, que había sido pactado con su empleador, calculada sobre el rubro «gratificación por cese laboral”. Luego de dejar en claro que “el pago de dicha suma está motivado por la extinción de la relación laboral y, además, que el distracto de ese vínculo implica, para el trabajador, la desaparición de la fuente productora de rentas gravadas”, y reiterar la doctrina sentada al resolver las causas D.1148.XLII «De Lorenzo, Amalia Beatriz (TF 21.504 – 1) cl DGI», sentencia del 17 de junio de 2009 y «Cuevas» (Fallos: 333:2193), determinó que “la aludida gratificación por cese laboral carece de la periodicidad y de la permanencia de la fuente necesaria para quedar sujeta al impuesto a las ganancias en los términos del art. 20, inc. 10, de la ley del mencionado tributo.” Negri, Fernando Horacio c/ EN-AFIP DGI  – Fallo N. 204. XLVIII.

 

Texto completo del fallo: http://www.csjn.gov.ar/docus/documentos/verdoc.jsp

39 comentarios de “«Negri, Fernando Horacio c/ EN – AFIP DGI» (15/7/2014) – CSJN –

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