Al ser consultada sobre el particular, la Dirección de Impuestos y Aduanas Nacionales -DIAN- emitió concepto en lo tocante a la aplicación del impuesto solidario por el COVID-19 cuando se trate de contratos de prestación de servicios profesionales y de apoyo a la gestión pública.
La naturaleza del contrato y su relación con los elementos del tributo
La DIAN manifestó que, en los eventos en los que una persona natural esté vinculada mediante 2 o más contratos de prestación de servicios profesionales y de apoyo a la gestión pública, se deberán tener en cuenta la totalidad de los pagos o abonos en cuenta para efectos de determinar la sujeción pasiva, el hecho generador, la base gravable y la tarifa.
En lo tocante a la base gravable, solamente se podrá detraer el primer millón ochocientos mil pesos sobre la totalidad de los pagos o abonos en cuenta, mensuales periódicos, a favor de la persona natural, sin consideración si dichos pagos o abonos en cuenta se originan en uno o varios contratos. En consecuencia, no es posible detraer un millón ochocientos mil pesos por cada contrato de prestación de servicios profesionales y de apoyo a la gestión pública.
Lo anterior, sostiene la entidad, en virtud del artículo 5° del Decreto Legislativo 568 de 2020, el cual establece que el primer millón ochocientos mil pesos del pago o abono en cuenta de los honorarios mensuales periódicos no integra la base gravable del impuesto solidario por el COVID-19.
Retención en la fuente a título del impuesto solidario por COVID-19
En los eventos en los que una persona natural esté vinculada mediante 2 o más contratos de prestación de servicios profesionales y de apoyo a la gestión pública, los agentes de retención deberán determinar, de conformidad con la información del SECOP, si procede la retención en la fuente a título del impuesto solidario por el COVID-19, y validar con el sujeto pasivo y con las demás entidades públicas la información. Una vez se valide si procede la retención en la fuente a título del impuesto solidario por el COVID-19, cada agente de retención deberá practicar la retención en la fuente en la proporción que le corresponda.
De esta manera, los agentes de retención a título del impuesto solidario por el COVID-19 tendrán que implementar los mecanismos que les permita determinar la procedencia de la retención en la fuente por concepto de dicho tributo, así como la proporción que les corresponde practicar a cada uno.
Consulte aquí el documento: DIAN-Concepto-2020-N0208221-513_20200504
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