Mediante el Decreto 1089 de 2020 el Ministerio de Hacienda y Crédito Público adicionó un capítulo al Título 1 de la Parte 2 del Libro 1 del Decreto 1625 de 2016, Único Reglamentario en Materia Tributaria. Lo anterior a efectos de reglamentar el descuento de IVA en la importación, formación, construcción o adquisición de activos fijos reales productivos.
Definición de activos fijos reales productivos
Para efectos del descuento de que trata el artículo 258-1 del Estatuto Tributario, son activos fijos reales productivos, aquellos que cumplan con la totalidad de las siguientes características:
- Sean activos fijos en los términos del artículo 60 del Estatuto Tributario;
- Sean bienes tangibles o corporales en los términos del Estatuto Tributario;
- Se adquieran, construyan, formen o importen para formar parte del patrimonio bruto del contribuyente;
- Participen de manera directa y permanente en la actividad productora de renta del contribuyente para la producción de bienes y/o servicios, y
- Sean susceptibles de depreciarse o amortizarse fiscalmente.
Definición de servicios necesarios para poner los activos fijos reales productivos en condiciones de utilización
Para efectos de la aplicación del artículo 258-1 del Estatuto Tributario son servicios necesarios para poner los activos fijos reales productivos en condiciones de utilización, aquellos servicios que sean imprescindibles para que los activos fijos reales productivos puedan ser utilizados.
Oportunidad del reconocimiento del descuento señalado en el artículo 258-1 del Estatuto Tributario
Los responsables del impuesto sobre las ventas IVA podrán descontar del impuesto sobre la renta a cargo, correspondiente al año en el que se efectúe su pago, o en cualquiera de los periodos gravables siguientes, el impuesto sobre las ventas -IVA pagado por la adquisición, construcción o formación e importación de activos fijos reales productivos, incluyendo el asociado a los servicios necesarios e imprescindibles para ponerlos en condiciones de utilización.
En el caso de los activos fijos reales productivos formados o construidos, el impuesto sobre las ventas -IVA podrá descontarse en el año gravable en que dicho activo se active y comience a depreciarse o amortizarse, o en cualquiera de los periodos gravables siguientes.
Reconocimiento del impuesto sobre las ventas -IVA pagado en la adquisición, construcción o formación e importación de activos fijos reales productivos como descuento o como mayor valor del costo o gasto del activo en el impuesto sobre la renta
El IVA pagado en la adquisición, construcción o formación e importación de activos fijos reales productivos podrá tener uno de los siguientes tratamientos:
1. Ser reconocido como un descuento en el impuesto sobre la renta, tal como lo señala el artículo 258-1 del Estatuto Tributario y el presente Capítulo; o
2. Como un mayor valor del costo o gasto del activo, el cual puede ser depreciable o amortizable.
Aplicación del descuento tributario establecido en el artículo 258 1 del Estatuto Tributario en las importaciones ordinarias
Los responsables del impuesto sobre las ventas -IVA podrán descontar del impuesto sobre la renta a cargo, correspondiente al año en el que se efectúe su pago, o en cualquiera de los periodos gravables siguientes, el impuesto sobre las ventas -IVA pagado por la importación ordinaria de activos fijos reales productivos, incluyendo el asociado a los servicios necesarios para ponerlos en condiciones de utilización.
Lo anterior será aplicable a las importaciones ordinarias de activos fijos reales productivos que se realicen a través de arrendamiento financiero o leasing con opción irrevocable de compra en los términos señalados en el artículo 1.2.1.27.5. de este Decreto.
Conservación de los soportes del descuento del artículo 258-1 del Estatuto Tributario
Los contribuyentes del impuesto sobre la renta y complementarios que apliquen el tratamiento de que trata el artículo 258-1 del Estatuto Tributario en la declaración del impuesto sobre la renta y complementarios, deberán conservar los recibos de pago, certificados, facturas de adquisición de los activos fijos reales productivos, declaraciones de importación y demás documentos necesarios para evidenciar el cumplimiento de los requisitos para la procedencia del respectivo tratamiento por el término señalado en el artículo 632 del Estatuto Tributario y artículo 46 de la Ley 962 de 2005.
Consulte aquí el documento: DECRETO 1089 DE 2020
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