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

Ver fallo completo

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

  1. Rattling great information can be found on web blog . “Never violate the sacredness of your individual self-respect.” by Theodore Parker.

  2. May I just say what a comfort to discover someone that genuinely knows what they are discussing on the net. You actually realize how to bring a problem to light and make it important. More and more people really need to check this out and understand this side of your story. I was surprised you aren’t more popular given that you most certainly have the gift.

  3. The Zune concentrates upon being a Portable Media Player. Not a internet browser. Not a game machine. Perhaps in the foreseeable future it’ll do even much better inside of those people areas, however for at the moment it really is a remarkable route toward organize and hear in direction of your tunes and films, and is devoid of peer inside that regard. The iPod’s benefits are its internet checking out and purposes. If these stable extra persuasive, quite possibly it is your excellent decision.

  4. The Zune concentrates upon becoming a Portable Media Player. Not a website browser. Not a recreation machine. Maybe inside of the potential it’ll do even greater inside individuals areas, yet for at this time it is a excellent way toward prepare and hear in the direction of your new music and movies, and is devoid of peer within that respect. The iPod’s strengths are its internet viewing and purposes. If people good extra persuasive, quite possibly it is your excellent selection.

  5. I and also my pals were found to be reading the nice helpful tips located on the website then unexpectedly got a terrible suspicion I had not thanked the website owner for those strategies. My women came passionate to study all of them and now have really been loving those things. Many thanks for being so thoughtful and for getting this sort of marvelous topics millions of individuals are really needing to be informed on. Our honest apologies for not saying thanks to you earlier.

  6. Sorry for the significant assessment, still I’m actually loving the new Zune, and assume this, as effectively as the good quality critiques some other americans include composed, will help you choose if it is the immediately decision for on your own.

  7. Thanks for posting this awesome article. I’m a long time reader but I’ve never been compelled to leave a comment. I subscribed to your blog and shared this on my Facebook. Thanks again for a great post!

  8. Fingers down, Apple’s app keep wins via a mile. It is really a large determination of all sorts of purposes vs a alternatively disappointed preference of a handful for Zune. Microsoft is made up of programs, primarily in the realm of games, but I’m not of course I’d require in the direction of bet upon the potential if this section is major in the direction of yourself. The iPod is a substantially improved conclusion within that scenario.

  9. The new Zune browser is shockingly favourable, nevertheless not as favourable as the iPod’s. It functions perfectly, still isn’t as fast as Safari, and is made up of a clunkier interface. If oneself at times system upon having the world wide web browser that’s not an issue, nonetheless if you happen to be coming up with in the direction of examine the world-wide-web alot versus your PMP then the iPod’s much larger exhibit and much better browser may well be crucial.

  10. Concerning me and my husband we have owned even further MP3 gamers above the years than I can rely, together with Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etcetera. But, the remaining couple several years I’ve settled down to just one line of players. Why? Due to the fact I was pleased to obtain how well-designed and fun to employ the service of the underappreciated (and broadly mocked) Zunes are.

  11. Thank you for writing this awesome article. I’m a long time reader but I’ve never been compelled to leave a comment. I subscribed to your blog and shared this on my Facebook. Thanks again for a great post!

  12. If you’re nonetheless on the fence: get your favorite earphones, mind down in the direction of a Most straightforward Obtain and talk to towards plug them into a Zune then an iPod and watch which just one sounds far better toward your self, and which interface would make your self smile further more. Then you’ll notice which is instantly for your self.

  13. Zune and iPod: Maximum folks review the Zune in direction of the Contact, yet immediately after viewing how skinny and surprisingly reduced and light it is, I take into account it in the direction of be a fairly one of a kind hybrid that brings together features of possibly the Contact and the Nano. It really is unbelievably colourful and stunning OLED display is slightly more compact than the touch screen, nevertheless the participant alone feels relatively a little bit smaller sized and lighter. It weighs concerning 2/3 as a great deal, and is appreciably lesser in width and height, When currently being just a hair thicker.

  14. Sorry for the substantial study, nonetheless I’m definitely loving the fresh new Zune, and hope this, as nicely as the high quality critiques some other us citizens consist of penned, will assist yourself determine if it can be the straight final decision for yourself.

  15. The Zune concentrates upon currently being a Transportable Media Player. Not a website browser. Not a activity machine. Potentially inside the long term it will do even far better inside those areas, but for presently it is a very good course towards prepare and pay attention to your tunes and videos, and is with out peer inside of that respect. The iPod’s strengths are its internet viewing and applications. If people stable much more compelling, possibly it is your simplest alternative.

  16. I am going to machines this analyze to Two styles of men and women: current Zune homeowners who are looking at an update, and individuals hoping towards determine in between a Zune and an iPod. (There are other players truly worth thinking about out there, together with the Sony Walkman X, still I expect this presents by yourself ample details in the direction of crank out an mindful preference of the Zune vs gamers other than the iPod line as well.)

  17. The clean Zune browser is incredibly Excellent, still not as very good as the iPod’s. It works effectively, yet isn’t really as immediate as Safari, and has a clunkier interface. If yourself occasionally software upon applying the world-wide-web browser that’s not an issue, yet if you happen to be designing towards browse the website alot towards your PMP then the iPod’s more substantial screen and far better browser could be necessary.

  18. Thanks for the superb write-up! I quite enjoyed finding out about it.I will be sure to save this website and definitely will return from now on. I would like to encourage you to definitely keep going with your wonderful posts, maybe comment on Ethereum trading as well, have a fine evening!

  19. Fingers down, Apple’s application retailer wins as a result of a mile. It really is a substantial number of all types of programs vs a in its place not happy selection of a handful for Zune. Microsoft contains Options, in particular in the realm of game titles, nonetheless I am not positive I’d will need in the direction of bet on the upcoming if this characteristic is crucial to by yourself. The iPod is a substantially superior preference within just that circumstance.

  20. I am going to gear this analyze toward 2 layouts of persons: latest Zune house owners who are looking at an improve, and human beings striving towards decide concerning a Zune and an iPod. (There are other players importance considering out there, which includes the Sony Walkman X, still I hope this features you more than enough details towards create an aware option of the Zune vs players other than the iPod line as very well.)

  21. You are certainly right and I trust you. Whenever you want, we could also talk regarding NYC parking ticket, something which fascinates me. The site is truly great, cheers!

  22. Thanks for publishing this awesome article. I’m a long time reader but I’ve never been compelled to leave a comment. I subscribed to your blog and shared this on my Twitter. Thanks again for a great post!

  23. Thank you very much for discussing this info, I saved the website. I’m additionally trying to find details on active credit card numbers, do you know the place where I might discover something such as this? I’ll return in a little while!

  24. Hullo there, just started to be mindful of your blog page through The Big G, and have found that it’s quite educational. I’ll be grateful for should you persist this informative article.

  25. Needed to compose you one tiny remark to be able to thank you yet again on your great techniques you’ve shown on this page. This has been really surprisingly generous of you to grant easily all a lot of people could have distributed as an ebook to earn some money on their own, chiefly since you might well have done it in case you wanted. The tips additionally served as a easy way to realize that most people have a similar keenness really like my very own to see more and more when considering this issue. I believe there are many more enjoyable times in the future for many who look over your blog post.

  26. I merely want to show you that I am new to writing a blog and pretty much admired your webpage. Very likely I am most likely to remember your blog post . You seriously have excellent article material. Delight In it for sharing with us all of your domain article

Los comentarios han sido cerrados.