May 18, 2020 – PRESUMPTION OF OPERATIONS INEXISTENCE. THE AUTHORITY HAS NO OBLIGATON TO NOTIFY THE DOCUMENTS ON WHICH IT BASED ITSELF FOR SUCH PRESUMPTION. Read More
May 16, 2020 – TAX RECEIPTS. IN COMPLIANCE WITH THE REQUIREMENTS WITHIN ARTICLES 29 AND 29-A FROM THE FEDERAL TAX CODE, DOES NOT FORCE THE AUTHORITIES TO AUTOMATICALLY RECOGNIZE THE TAX EFFECTS DERIVED FROM THE PREVIOUSLY STATED ARTICLES Read More
February 26, 2020 – BUSINESS REASON. THE AUTHORITIES CAN CONSIDER THE ABSENCE OF BUSINESS REASON AS ONE OF THE ELEMENTS THAT DETERMINE THE LACK OF MATERIALITY OF AN OPERATION, CASE WHICH, THE BURDEN OF PROOF TO PROVE THE EXISTENCE AND REGULARITY OF THE OPERATION, IS THE TAXPAYERS. Read More
February 13, 2020 – ANNULMENT REQUEST OF A SIMULATED ACT. IS NOT A PRECONDITION TO DISREGARD THE TAX EFFECTS OF NONEXISTENT OPERATIONS. Read More
January 26, 2020 – DOUBLE TAXATION. THE COMMENTS TO THE MODEL TAX CONVENTION ON INCOME AND ON CAPITAL OF THE ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT (OECD), CONSTITUTES ONE OF THE INSTRUMENTS TO CONSTRUE THE PROVISIONS EXISTING IN THE CONVENTION. Read More
January 20, 2020 – SOCIAL CAPITAL INCREASE, FOR THE VARIABLE STOCK COMPANIES. FOR THE AGREEMENTS TO TAKE EFFECT FOR THIRD PARTIES, THEY SHOULD BE DONE VIA EXTRAORDINARY ASSEMBLY AND MUST BE LEGALIZED AT A NOTARY PUBLIC. Read More
January 16, 2020 – PRESUMPTION OF OPERATIONS INEXISTENCE. MOTIVATION OF THE OFFICIAL LETTER WITH WHICH THE PROCEDURE REGULATED IN ARTICLE 69-B OF THE FEDERAL TAX CODE STARTS. Read More
January 15, 2020 – PATRIMONIAL RESPONSIBILITY OF THE STATE, INDEMNIFICATION, MECHANICS OF QUANTIFICATION. Read More
January 13, 2020 – DOUBLE TAXATION. USE OF THE COMMENTS ON THE OECD MODEL, IN ACCORDANCE WITH THE VIENNA CONVENTION. Read More
January 13, 2020 – THE TAX AUTHORITIES POWER TO VERIFY. IN THEIR EXERCISE, THEY COULD RIGHTFULLY IGNORE THE TAX EFFECTS OF AN ACT INTENDED TO HAVE LEGAL EFFECTS REGISTER IN THEIR BOOKS, IF THERE IS NO MATERIALITY. Read More
