La CSJN confirmó la determinación de oficio realizada por AFIP en cuanto entendió que el depósito en efectivo en cuenta bancaria para cancelar operaciones constituye un sistema de pagos organizado, alcanzado por el impuesto a los créditos y débitos en cuenta bancaria. En un reciente pronunciamiento de la Corte Suprema de Justicia de la Nación en los autos caratulados «Piantoni Hnos. SACIFI y A c/ Dirección General Impositiva s/ recurso directo de organismo externo», se ratificó la determinación de AFIP en relación al impuesto a los créditos y débitos por entender que el sistema utilizado por la actora para cancelar sus deudas con un proveedor (depósito en efectivo en las cuentas de éste, de modo que el pago se efectuaba sin que Piantoni utilizara sus propias cuentas bancarias) constituía un sistema organizado de pagos en los términos de la Ley 25.413, decreto 380/01 y resolución general de AFIP 1135/2001. La Corte Suprema de Justicia de la Nación definió al sistema organizado de pagos como aquél que permita sustituir el uso de cuentas bancarias en el ejercicio de una actividad económica y que razonablemente pudiera considerarse que estuviese reemplazando una operación que no fue realizada a través de un débito o crédito en las cuentas bancarias de quien efectuó dicho movimiento. Todo ello siempre y cuando, dichos movimientos o entregas de fondos sean efectuados por cuenta propia y/o ajena en el ejercicio de actividades económicas. Este sistema fue creado por las resoluciones aludidas con la finalidad de evitar la elusión del impuesto en los términos originariamente previstos por la Ley. Adicionalmente, para darle la razón a la demandada la Corte sostuvo: • Que los elementos esenciales del tributo, su hecho imponible, los sujetos obligados, la base imponible y las exenciones han sido expresamente establecidos por una ley, en sentido formal y material, emanada del Congreso de la Nación. • Que con la disposición en cuestión no se pretende gravar cualquier movimiento de fondos, sino únicamente aquel que razonablemente pudiera considerarse que estuviese “reemplazando” una operación que no fue realizada a través de un débito o crédito en las cuentas bancarias de quien efectuó dicho movimiento.• Que la resolución general 1135/2001 de AFIP no ha modificado ninguno de los elementos esenciales del tributo creado por el legislador ni ha pretendido ampliar los supuestos comprendidos en el ordenamiento legal abarcando situaciones nuevas o distintas de las previstas en aquel. Por el contrario, mediante ella se han precisado los casos en que tienen cabida en el ordenamiento legal con la finalidad de evitar la elusión del impuesto en los términos en los que este había sido originariamente establecido por el legislador. En base a estos argumentos, la Corte consideró que la determinación de oficio era correcta y rechazó la pretensión del contribuyente.
Hello there, just became aware of your blog through
Google, and found that it’s truly informative. I am going to watch out for brussels.
I will be grateful if you continue this in future.
Many people will be benefited from your writing.
Cheers! Najlepsze escape roomy
Very interesting info!Perfect just what I was searching for!?
I think this is a real great blog articleMuch thanks again Fantastic
Wow many of terrific data!
Wow, this was a really quality post In theory I’d like to write like this too – taking time and actual effort to make a good post… but what can I say… I procrastinate alot and never appear to get something done
Real wonderful info can be found on web blog.
Euro travel
Serious Use Alternative 1 hydrocortisone decreases effects of measles rubeola vaccine by pharmacodynamic antagonism order priligy online usa There are several anecdotal accounts of cost savings associated with local implementation of practice guidelines, often with attendant improvements in care
Oh my goodness! Amazing article dude! Many thanks, However I am having difficulties with your RSS. I don’t understand the reason why I can’t subscribe to it. Is there anybody else getting identical RSS issues? Anyone that knows the solution will you kindly respond? Thanks!
This web site truly has all the information and facts I wanted concerning this subject and didn’t know who to ask.
Greetings! Very helpful advice in this particular article! It is the little changes that make the most important changes. Many thanks for sharing!
Way cool! Some extremely valid points! I appreciate you writing this article and the rest of the website is also really good.
An interesting discussion is definitely worth comment. I do believe that you should write more on this issue, it might not be a taboo matter but usually people do not talk about these subjects. To the next! Best wishes!
I need to to thank you for this wonderful read!! I certainly loved every bit of it. I have got you book-marked to check out new things you post…
Düşük bahislerle uzun süre oynayarak Jammin’ Jars’ta harika kazançlar elde ettim!
Great information. Lucky me I found your blog by chance (stumbleupon). I’ve saved as a favorite for later.
I truly love your blog.. Great colors & theme. Did you make this site yourself? Please reply back as I’m trying to create my own blog and would like to know where you got this from or what the theme is named. Cheers.
Very nice write-up. I absolutely appreciate this website. Keep writing!
This blog was… how do you say it? Relevant!! Finally I’ve found something that helped me. Thank you.
Can I simply say what a relief to discover someone that actually understands what they are talking about on the web. You definitely understand how to bring an issue to light and make it important. More people ought to read this and understand this side of the story. I can’t believe you are not more popular because you surely possess the gift.
Greetings! Very helpful advice in this particular post! It is the little changes that will make the biggest changes. Many thanks for sharing!
Saved as a favorite, I really like your site!
There’s definately a lot to learn about this issue. I love all of the points you made.
It’s difficult to find well-informed people about this subject, but you seem like you know what you’re talking about! Thanks
I was able to find good info from your blog articles.
Hi there! I could have sworn I’ve visited this blog before but after going through some of the posts I realized it’s new to me. Regardless, I’m definitely delighted I stumbled upon it and I’ll be book-marking it and checking back regularly!
Saved as a favorite, I love your website.
An outstanding share! I have just forwarded this onto a coworker who has been doing a little research on this. And he actually bought me dinner because I stumbled upon it for him… lol. So let me reword this…. Thank YOU for the meal!! But yeah, thanx for spending some time to talk about this matter here on your website.
I’m amazed, I have to admit. Rarely do I come across a blog that’s both equally educative and interesting, and without a doubt, you have hit the nail on the head. The problem is an issue that not enough people are speaking intelligently about. I’m very happy I came across this during my search for something relating to this.
You made some decent points there. I looked on the web for more information about the issue and found most people will go along with your views on this website.
Howdy! I could have sworn I’ve been to your blog before but after looking at a few of the posts I realized it’s new to me. Anyhow, I’m certainly delighted I discovered it and I’ll be bookmarking it and checking back often.
Having read this I believed it was rather informative. I appreciate you finding the time and effort to put this information together. I once again find myself personally spending a significant amount of time both reading and posting comments. But so what, it was still worthwhile!
I love reading through a post that can make men and women think. Also, thanks for allowing for me to comment.
Greetings! Very useful advice within this article! It’s the little changes that will make the largest changes. Thanks a lot for sharing!
This is a topic that is near to my heart… Many thanks! Where are your contact details though?
May I simply just say what a relief to find somebody who actually knows what they are talking about on the net. You certainly realize how to bring an issue to light and make it important. More people really need to check this out and understand this side of your story. I was surprised that you aren’t more popular because you most certainly possess the gift.
Nice post. I learn something new and challenging on websites I stumbleupon every day. It will always be exciting to read through content from other writers and practice something from other web sites.
After going over a handful of the articles on your web site, I really appreciate your technique of blogging. I added it to my bookmark site list and will be checking back soon. Please visit my website too and let me know how you feel.
Hello there! I could have sworn I’ve been to this blog before but after looking at many of the posts I realized it’s new to me. Regardless, I’m certainly pleased I came across it and I’ll be book-marking it and checking back often.
I wanted to thank you for this wonderful read!! I certainly loved every little bit of it. I’ve got you saved as a favorite to check out new stuff you post…
Good web site you’ve got here.. It’s hard to find high-quality writing like yours nowadays. I honestly appreciate people like you! Take care!!
Hi there! This post could not be written any better! Going through this article reminds me of my previous roommate! He always kept preaching about this. I will send this information to him. Fairly certain he’ll have a very good read. Many thanks for sharing!
Having read this I thought it was extremely informative. I appreciate you finding the time and energy to put this informative article together. I once again find myself spending a significant amount of time both reading and leaving comments. But so what, it was still worth it.
There’s certainly a lot to know about this topic. I like all the points you have made.
It’s hard to come by well-informed people in this particular subject, but you seem like you know what you’re talking about! Thanks
Oh my goodness! Incredible article dude! Many thanks, However I am having issues with your RSS. I don’t know the reason why I cannot subscribe to it. Is there anybody else having the same RSS problems? Anybody who knows the answer can you kindly respond? Thanks!!
I absolutely love your website.. Excellent colors & theme. Did you create this website yourself? Please reply back as I’m wanting to create my very own site and want to learn where you got this from or what the theme is named. Kudos!
Oh my goodness! Impressive article dude! Thank you, However I am having troubles with your RSS. I don’t understand the reason why I cannot join it. Is there anybody getting identical RSS problems? Anyone who knows the answer will you kindly respond? Thanks!!
I’m more than happy to discover this great site. I need to to thank you for ones time just for this fantastic read!! I definitely liked every little bit of it and i also have you book-marked to see new things on your website.
I was able to find good advice from your articles.
This blog was… how do I say it? Relevant!! Finally I’ve found something which helped me. Thank you.
Hi, I do believe this is an excellent site. I stumbledupon it 😉 I will come back yet again since i have book-marked it. Money and freedom is the greatest way to change, may you be rich and continue to guide others.
This is a topic which is close to my heart… Best wishes! Where are your contact details though?
Nice post. I learn something new and challenging on blogs I stumbleupon on a daily basis. It’s always interesting to read content from other authors and use something from their web sites.
Having read this I believed it was really enlightening. I appreciate you spending some time and effort to put this information together. I once again find myself spending a significant amount of time both reading and leaving comments. But so what, it was still worthwhile!
Great blog you’ve got here.. It’s hard to find high-quality writing like yours nowadays. I seriously appreciate people like you! Take care!!
Good blog post. I absolutely appreciate this site. Continue the good work!
Oh my goodness! Awesome article dude! Thank you so much, However I am encountering issues with your RSS. I don’t know the reason why I am unable to join it. Is there anybody getting similar RSS problems? Anybody who knows the answer will you kindly respond? Thanks!
After I originally commented I seem to have clicked the -Notify me when new comments are added- checkbox and now each time a comment is added I receive 4 emails with the same comment. Perhaps there is a way you can remove me from that service? Cheers.
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
I have actually fought with blood sugar fluctuations for several years, and it really impacted my
power levels throughout the day. Because starting Sugar Defender, I really feel a lot more balanced and alert, and I do not experience
those afternoon sags anymore! I love that it’s a natural remedy that functions
without any extreme negative effects. It’s truly been a game-changer for me
Hi, I do think this is an excellent site. I stumbledupon it 😉 I may revisit yet again since I saved as a favorite it. Money and freedom is the best way to change, may you be rich and continue to guide other people.
I used to be able to find good information from your articles.
Jonkers IJ, et al cialis with priligy
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Nice post. I learn something new and challenging on blogs I stumbleupon everyday. It’s always interesting to read articles from other writers and practice something from other sites.
Excellent post! We will be linking to this particularly great content on our site. Keep up the great writing.
Good day! I could have sworn I’ve been to this site before but after going through some of the posts I realized it’s new to me. Nonetheless, I’m definitely pleased I discovered it and I’ll be book-marking it and checking back often!
I could not resist commenting. Perfectly written!
I quite like reading through an article that can make men and women think. Also, thanks for allowing me to comment.
En sevdiğim slot oyunu Jammin’ Jars, her spin büyük bir kazanç şansı sunuyor!
Good info. Lucky me I recently found your website by chance (stumbleupon). I’ve saved as a favorite for later.
Deneme bonusu sayesinde hiç para yatırmadan büyük kazançlar sağladım!
Great site you’ve got here.. It’s hard to find good quality writing like yours these days. I really appreciate people like you! Take care!!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
En sevdiğim slot oyunu Sweet Bonanza, kazançlarım sürekli artıyor.
https://suncity888.dad/
Bahis siteleri deneme bonusu ile bedava bahis yaparak büyük kazançlar sağlamak çok keyifli!
Bu casino’nun sunduğu bonuslar ile slot oyunlarında daha uzun süre oynayabiliyorum.
Bu casino’nun sunduğu slot oyunları, her gün büyük kazançlar sağlıyor.
Slot oyunlarının kazandırma oranları çok yüksek, bu casino favorim oldu!
Oh my goodness! Awesome article dude! Thank you, However I am going through troubles with your RSS. I don’t know the reason why I am unable to subscribe to it. Is there anybody else having similar RSS problems? Anybody who knows the answer can you kindly respond? Thanx!!
Hello there! Do you know if they make any plugins to
help with Search Engine Optimization? I’m trying
to get my site to rank for some targeted keywords but I’m not seeing very good success.
If you know of any please share. Thank you! You can read similar blog here: Eco product
I’m amazed, I must say. Rarely do I come across a blog that’s both equally educative and engaging, and without a doubt, you have hit the nail on the head. The problem is an issue that not enough people are speaking intelligently about. Now i’m very happy I came across this in my hunt for something concerning this.
I absolutely love your blog.. Very nice colors & theme. Did you make this site yourself? Please reply back as I’m trying to create my own personal site and would like to know where you got this from or just what the theme is named. Kudos!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
I was able to find good info from your content.
Aw, this was an exceptionally nice post. Spending some time and actual effort to produce a very good article… but what can I say… I hesitate a whole lot and never manage to get nearly anything done.
Right here is the right web site for everyone who wants to understand this topic. You realize a whole lot its almost hard to argue with you (not that I really will need to…HaHa). You definitely put a new spin on a topic that has been written about for a long time. Great stuff, just great.
I truly love your blog.. Great colors & theme. Did you develop this web site yourself? Please reply back as I’m attempting to create my own personal website and would like to find out where you got this from or exactly what the theme is called. Thanks.
Nice post. I learn something new and challenging on websites I stumbleupon on a daily basis. It’s always interesting to read through articles from other writers and practice a little something from their web sites.
I like it whenever people get together and share thoughts. Great website, stick with it.
Daga – Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Spot on with this write-up, I seriously believe this amazing site needs far more attention. I’ll probably be back again to read through more, thanks for the advice!
I blog quite often and I seriously thank you for your content. This great article has truly peaked my interest. I am going to book mark your site and keep checking for new information about once a week. I opted in for your Feed too.
That is a very good tip particularly to those new to the blogosphere. Simple but very accurate information… Many thanks for sharing this one. A must read article!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
You have made some good points there. I looked on the web for more info about the issue and found most people will go along with your views on this website.
Slot oyunlarının grafikleri ve sesleri bu casino’da gerçekten etkileyici, oyunlar çok keyifli.
I blog quite often and I seriously thank you for your information. This great article has truly peaked my interest. I’m going to book mark your blog and keep checking for new details about once per week. I opted in for your Feed too.
This is a topic that is close to my heart… Cheers! Where can I find the contact details for questions?
Good blog you’ve got here.. It’s difficult to find high quality writing like yours nowadays. I seriously appreciate individuals like you! Take care!!
The very next time I read a blog, Hopefully it does not fail me as much as this particular one. I mean, I know it was my choice to read through, but I actually believed you would have something interesting to say. All I hear is a bunch of whining about something you could possibly fix if you were not too busy searching for attention.
Pretty! This was a really wonderful post. Thanks for supplying this info.
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Known for its very wealthy heritage, Limerick is crammed with natural magnificence and rural appeal.
Greetings, I think your blog could be having internet browser compatibility issues. When I take a look at your web site in Safari, it looks fine however when opening in I.E., it has some overlapping issues. I just wanted to provide you with a quick heads up! Aside from that, wonderful site.
This is the right web site for anybody who really wants to understand this topic. You realize so much its almost tough to argue with you (not that I actually would want to…HaHa). You definitely put a new spin on a subject which has been discussed for a long time. Great stuff, just excellent.
You need to take part in a contest for one of the highest quality blogs on the net. I’m going to highly recommend this website!
Hello there! This article couldn’t be written any better! Going through this article reminds me of my previous roommate! He always kept talking about this. I will forward this information to him. Pretty sure he’ll have a good read. I appreciate you for sharing!
Daga
Next time I read a blog, Hopefully it does not disappoint me as much as this particular one. After all, Yes, it was my choice to read through, but I truly thought you’d have something helpful to say. All I hear is a bunch of whining about something you can fix if you were not too busy seeking attention.
mk sports Quay lén phụ nữ
This excellent website really has all the information and facts I wanted about this subject and didn’t know who to ask.
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
An impressive share! I’ve just forwarded this onto a coworker who was conducting a little research on this. And he in fact ordered me breakfast simply because I discovered it for him… lol. So allow me to reword this…. Thanks for the meal!! But yeah, thanx for spending time to discuss this issue here on your web page.
It’s hard to come by experienced people in this particular subject, but you sound like you know what you’re talking about! Thanks
sugar defender official website For several years,
I’ve battled unpredictable blood sugar level swings
that left me feeling drained and inactive. But considering
that integrating Sugar Defender right into my routine, I’ve observed a considerable enhancement
in my general energy and security. The dreaded mid-day
distant memory, and I value that this natural solution accomplishes these results with no undesirable or damaging reactions.
truthfully been a transformative exploration for me.
When I originally left a comment I appear to have clicked on the -Notify me when new comments are added- checkbox and from now on every time a comment is added I recieve 4 emails with the exact same comment. Is there a means you are able to remove me from that service? Thanks a lot.
This is a topic that’s near to my heart… Take care! Where can I find the contact details for questions?
bookmarked!!, I really like your blog.
Hello there, I do think your blog could possibly be having internet browser compatibility problems. When I look at your site in Safari, it looks fine however, if opening in IE, it’s got some overlapping issues. I simply wanted to provide you with a quick heads up! Aside from that, fantastic blog.
It’s nearly impossible to find educated people on this topic, but you sound like you know what you’re talking about! Thanks
Daga – Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
This is the right website for anyone who would like to understand this topic. You understand so much its almost hard to argue with you (not that I personally would want to…HaHa). You certainly put a new spin on a subject that has been written about for decades. Wonderful stuff, just excellent.
There is definately a great deal to learn about this topic. I like all the points you’ve made.
Hello, There’s no doubt that your website could be having browser compatibility problems. When I look at your website in Safari, it looks fine but when opening in I.E., it’s got some overlapping issues. I just wanted to provide you with a quick heads up! Besides that, great blog.
You need to take part in a contest for one of the greatest websites on the net. I’m going to recommend this web site!
Hello there! This blog post couldn’t be written much better! Looking through this article reminds me of my previous roommate! He constantly kept preaching about this. I am going to send this information to him. Fairly certain he’s going to have a good read. Thank you for sharing!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
You’ve made some really good points there. I checked on the web to learn more about the issue and found most individuals will go along with your views on this web site.
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
I have to thank you for the efforts you have put in writing this website. I am hoping to see the same high-grade content by you later on as well. In truth, your creative writing abilities has encouraged me to get my own site now 😉
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
I would like to thank you for the efforts you’ve put in penning this website. I am hoping to view the same high-grade blog posts from you later on as well. In truth, your creative writing abilities has encouraged me to get my own site now 😉
Bahis siteleri deneme bonusu ile oyunlara sıfır yatırımla başlamak gerçekten harika!
https://f8bet.news/
88CLB
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
https://km88.band/
Great information. Lucky me I recently found your website by chance (stumbleupon). I’ve bookmarked it for later.
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
I want to to thank you for this great read!! I certainly enjoyed every bit of it. I have you bookmarked to check out new things you post…
En sevdiğim slot oyunu Fire in the Hole, her spin heyecan verici ve kazanç dolu.
An outstanding share! I have just forwarded this onto a co-worker who had been doing a little research on this. And he in fact bought me lunch because I discovered it for him… lol. So let me reword this…. Thank YOU for the meal!! But yeah, thanx for spending the time to talk about this topic here on your website.
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
I absolutely love your website.. Pleasant colors & theme. Did you build this web site yourself? Please reply back as I’m trying to create my own website and want to learn where you got this from or what the theme is named. Appreciate it.
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Hi, I do believe this is an excellent site. I stumbledupon it 😉 I may return once again since I book marked it. Money and freedom is the greatest way to change, may you be rich and continue to guide other people.
I really love your blog.. Great colors & theme. Did you build this amazing site yourself? Please reply back as I’m wanting to create my own personal site and would like to learn where you got this from or exactly what the theme is named. Thank you.
Your style is unique in comparison to other folks I’ve read stuff from. Many thanks for posting when you’ve got the opportunity, Guess I’ll just bookmark this page.
Casino’nun sunduğu slot turnuvaları sayesinde ekstra ödüller kazanmak çok kolay ve eğlenceli.
You have made some good points there. I checked on the web to find out more about the issue and found most individuals will go along with your views on this website.
Good post. I’m going through some of these issues as well..
Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
Fun88 – Introducing to you the most prestigious online entertainment address today. Visit now to experience now!
http://88clbcom.net
https://sky88.how
trang chủ km88
Bu bahis sitesinin sunduğu deneme bonusu ile hemen büyük kazançlar elde ettim!
Deneme bonusu ile bahis yaparken para kaybetme riskim olmadı, sadece kazandım!
Deneme bonusu kullanarak ilk kazancımı hiç para yatırmadan elde ettim!