¿Tuvo que pagar el impuesto solidario? DIAN se pronuncia sobre la inexequibilidad del Decreto 568 de 2020

¿Tuvo que pagar el impuesto solidario? DIAN se pronuncia sobre la inexequibilidad del Decreto 568 de 2020

La Sudirección de Gestión Normativa y Doctrina de la DIAN se pronunció luego de que la Corte Constitucional, mediante la sentencia C-293 de 2020, declarase la inexequibilidad del denominado “impuesto solidario” creado con ocasión del COVID-19. Para más información sobre este tema consulte:

Consideraciones preliminares

La DIAN recordó que mediante el comunicado número 32 del 5 y 6 de agosto de 2020 la Corte Constitucional manifestó, una vez analizado el Decreto Legislativo 568 de 2020, su decisión de declarar la inexequibilidad del “impuesto solidario”:

“Primero. Declarar INEXEQUIBLES los artículos 1°, 2°, 3°, 4°, 5°, 6°, 7° y 8° del Decreto Legislativo 568 de 2020, “por el cual se crea el impuesto solidario por el COVID 19, dentro del Estado de Emergencia Económica, Social y Ecológica dispuesto en el Decreto Legislativo 417 de 2020”. Esta decisión tendrá efectos RETROACTIVOS. En consecuencia, los dineros que los sujetos pasivos del impuesto han cancelado se entenderán como abono del impuesto de renta para la vigencia 2020, y que deberá liquidarse y pagarse en 2021.

Segundo. Declarar EXEQUIBLES los artículos 9°, 10, 11, 12, 13 y 14 del Decreto Legislativo 568 de 2020, “por el cual se crea el impuesto solidario por el COVID 19, dentro del Estado de Emergencia Económica, Social y Ecológica dispuesto en el Decreto Legislativo 417 de 2020”, salvo las siguientes expresiones que se declaran INEXEQUIBLES:

– “con salarios y honorarios mensuales periódicos inferiores a diez millones de pesos ($10.000.000.00)”, contenida en el inciso 1° del artículo 9°.

– “de salarios y honorarios mensuales periódicos inferiores a diez millones de pesos ($10.000.000.00)”, contenida en el inciso 2° del artículo 9°.

– La tabla contenida en el primer inciso del artículo 9°.

– “El aporte solidario voluntario por el Covid 19 de que trata el presente artículo no es aplicable al talento humano en salud que preste sus servicios a pacientes con sospecha o diagnóstico de coronavirus Covid 19 incluidos quienes realicen vigilancia epidemiológica y que por consiguiente, están expuestos a riesgos de contagio, así como los miembros de la fuerza pública.”, correspondiente al inciso final del artículo 9°.

– “los valores retenidos en la fuente a título del impuesto solidario por el Covid 19 y” contenida en el inciso 1° del artículo 12.

– “del impuesto solidario por el Covid 19 y” contenida en el inciso 2° del artículo 12.

– “El valor total de las retenciones en la fuente a título del impuesto solidario por el Covid 19 constituyen el valor total del impuesto y no habrá́ lugar a la presentación de la declaración del impuesto”, correspondiente al inciso 3° del artículo 12.

– “Al impuesto solidario por el Covid 19 le son aplicables en lo que resulte compatible, las disposiciones sustantivas del impuesto sobre la renta y complementarios, procedimentales y sancionatorias previstas en el Estatuto Tributario”, correspondiente al inciso 1o del artículo 13.”

Pronunciamiento de la DIAN

La sentencia C-293 de 2020 estableció que la decisión tiene efectos retroactivos, en el sentido de establecer que los dineros que los sujetos pasivos del impuesto han cancelado se entenderán como abono del impuesto de renta para la vigencia 2020, y que deberá liquidarse y pagarse en 2021.

Así las cosas, los valores que hayan sido objeto de retención en la fuente a título del impuesto solidario por el Covid 19 no pueden ser objeto de reintegro por parte de los agentes de retención. Lo anterior teniendo en cuenta el mecanismo de abono en renta establecido por la Sentencia C-293 de 2020.

En vista de lo anterior, los contribuyentes, bien sean servidores públicos, contratistas o pensionados, podrán abonar los valores retenidos por concepto del impuesto solidario por el Covid 19 en la declaración del impuesto sobre la renta del periodo gravable 2020, y que deberá liquidarse y pagarse en 2021.

Por consiguiente, si se generan saldos a favor en la declaración del impuesto sobre la renta del año gravable 2020 (que se liquida y paga en 2021), con ocasión del abono del impuesto solidario por el Covid 19, dichos saldos a favor podrán ser solicitados en devolución y/o compensación, de conformidad con las disposiciones correspondientes del Estatuto Tributario y el reglamento.

Consulte aquí el documento: DIAN-Concepto-2020-N0208221-1062_20200828

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