La planificación fiscal internacional y su relación con los precios de transferencia en el Perú

• Autor: Ulloa Siccha, Javier Leopoldo
• Formato: tesis doctoral
• Fecha de Publicación: 2012
• Institución: Universidad Nacional de Trujillo
• Repositorio: UNITRU-Tesis
• Lenguaje: español
• OAI Identifier: oai:dspace.unitru.edu.pe:20.500.14414/5966
• Enlace del recurso: https://hdl.handle.net/20.500.14414/5966
• Nivel de acceso: acceso abierto
• Materia: Planificación fiscal internacional, Precios de transferencia en el perú

The economic internationalization has incremented the incomes fear of the Administrations Tributaries of the different statuses on the deslocalization risks. One of the mechanisms that the companies (principally multinational companies) as mechanisms of reduction of the tributary load utilize consists in the transferential utilization of the pricings as mechanisms translational of incomes and gainings among the multinational group's different parts and in consequence enter different tributary jurisdictions. From the optic district attorney the pricings transferential they acquire significant importance at the present time, due to the intensification of the international traffic and to the fact of that national dealings's great number and internationals accomplish to the linked, inside of the entrepreneurial groups according to United Nations's Organization over the 60 themselves. The theme of the fiscal planning within the tributary right has turned add up relevance, since not only it limits himself to the cost-reducing international space but to the whole exhaustive analysis, for the one that companies search for to reduce the tributary load. It implies having knowledge on the tributary applicable standards that are permissible juridically and that do not cause a cost-reducing damage to administration, strategies. Even though the fiscal international planning is based on the cost-reducing freedom, this has its limits, as they are: Undercapitalization, appropriate expenses of fiscal paradises and the value of market. Even though the contributor indicates to reduce his tributary load, it does not imply than all fiscal saving configure an evasion or an illicit hint. The progressive internationalization of economies leads to present the need to accomplish a fiscal international planning, for the sake of minimizing the load fiscal, which affects on investments or appropriate incomes of different statuses. The role of the fiscal international planning involves to look for the best structure to develop of efficient way; That is, you should have in account, the following aspects: Juridical certainty of the presented operation, the uncertainty of legislative changes, the flexibility to reorganize the entrepreneurial structure, the mobility of the used resources, the diferimiento in the payment of the tributes, the fiscal united load and the maximum profitability. The fiscal planification international based on actual and efficient strategy calls for in order to maximizing gainings in the option economy. In order to it, resort to tributary standards applicable to obtain the juridical certainty in the commercial operations; however, he must avoid the strategies abuse than of manner once was concealed and once was simulated, Let them configure operations enter linked with inferior moral values or elders, whose only purpose be to decrease the fiscal load.