Preguntas Frecuentes 17 Claves sobre el Impuesto a los Grandes Patrimonios

17 Claves sobre el Impuesto a los Grandes Patrimonios

17 Claves sobre el Impuesto a los Grandes Patrimonios

Debido a que la Ley que crea el Impuesto a los Grandes Patrimonios, publicada en la Gaceta Oficial N° 41.667, de fecha 03 de julio de 2019, presentaba errores materiales, el pasado 16 de agosto de 2019, en la Gaceta Oficial No.  41.696, se publicaron las correspondientes correcciones, quedando así la mencionada Ley:

  1. Son contribuyentes de este impuesto los sujetos pasivos especiales, naturales y jurídicos, cuyo patrimonio sea igual o superior a 150.000.000 de Unidades Tributarias (U.T.).
  1. De acuerdo al criterio de territorialidad, los contribuyentes deberán cancelar este tributo considerando los siguientes aspectos:
  • Las personas naturales y jurídicas residentes en el país, por la totalidad del patrimonio, cualquiera sea el lugar donde se encuentren ubicados los bienes o se puedan ejercer los derechos que lo conforman
  • Las personas naturales y jurídicas no residentes en el país, por los bienes que se encuentren ubicados en el territorio nacional, así como por los derechos que se puedan ejercer en el país.
  • Las personas naturales y jurídicas de nacionalidad venezolana no residentes en el país, por los bienes que se encuentren ubicados en el territorio nacional, así como por los derechos que se puedan ejercer en el país.
  • Cuando las personas no residentes en el país posean establecimiento permanente en el territorio nacional, serán además contribuyentes por la totalidad del patrimonio atribuible a dicho establecimiento. 
  1. Se considera que una persona natural es residente cuando:
  • Permanezca en el país por un período continuo, o discontinuo, superior a 183 días del período de imposición.
  • Se encuentra en el país el núcleo principal o la base de sus actividades o intereses económicos.
  • Tiene nacionalidad venezolana y es funcionario público, aun cuando sus actividades o intereses económicos se encuentre en el extranjero.
  • Tiene nacionalidad venezolana pero su residencia fiscal corresponde a un país de baja imposición fiscal, salvo cuando dicho país haya celebrado un acuerdo de intercambio de información tributaria con Venezuela.
  1. Se presume que una persona natural es residente cuando:
  • Haya establecido su lugar de habitación o tenga una vivienda principal en el país.
  • Sea de nacionalidad venezolana.
  • Su cónyuge no separado legalmente o sus hijos menores de edad que dependan de él, hayan permanecido en el país por un periodo continuo, o discontinuo, superior a 183 días del período de imposición.
  1. Se considera que una persona jurídica es residente cuando se produzca cualquiera de las siguientes causas:
  • Haya sido constituida conforme a las leyes venezolanas.
  • Tenga su domicilio fiscal o estatutario en el país.
  • Tenga su sede de dirección efectiva en el país. 
  1. A efectos de esta ley se consideran ubicados en Venezuela: 
  • Los derechos sobre bienes inmuebles ubicados en el territorio nacional.
  • Las naves, aeronaves, buques, accesorios de navegación y vehículos automotores de matrícula nacional.
  • Las naves y vehículos de matrícula extranjera, que hayan permanecido en el país 120 días, continuos o discontinuos, durante el periodo de imposición.
  • Los títulos representativos del capital social o equivalente, emitido por sociedades venezolanas.
  • Las piedras preciosas, minerales, obras de arte y joyas.
  1. Algunos casos especiales de atribución de patrimonio son: 
  • En los casos de arrendamiento financiero contratados con empresas regidas por la legislación que regula los bancos y otras instituciones financieras, el bien objeto de arrendamiento se atribuirá al arrendatario.
  • En los casos de contratos de fideicomiso, el bien objeto de fideicomiso se atribuirá al beneficiario.
  • En los casos de personas jurídicas, los bienes de uso personal de los accionistas se imputarán al patrimonio de la persona natural.
  1. Una vez declarado el Patrimonio, su propiedad o posesión se presume para los períodos de imposición siguientes, salvo prueba de transmisión o pérdida.
  1. Las exenciones de este impuesto son:
  • La República y demás entes político territoriales.
  • El Banco Central de Venezuela
  • Los entes descentralizados
  • La vivienda registrada como principal ante la Administración Tributaria.
  • Los efectos personales y del hogar, utensilios domésticos y demás bienes muebles de uso particular del contribuyente
  • Las prestaciones sociales y demás beneficios derivados de las relaciones laborales
  • Los bienes y derechos comunales
  • Los activos invertidos en actividades agrícolas, pecuarias, acuícolas, piscícolas y pesqueras utilizados a nivel primario.
  • La obra propia de los artistas mientras sean propiedad del autor
  • Los bienes situados en el país, pertenecientes a las misiones diplomáticas y consulares extranjeras, en la medida y con las limitaciones que establezcan los convenios internacionales aplicables y a condición de reciprocidad.
  1. La base imponible del impuesto será el resultado de sumar el valor total de los bienes y derechos, excluidos los pasivos y el valor de las cargas y gravámenes que recaigan sobre los bienes, así como, los bienes y derechos exentos o exonerados.
  1. La Administración Tributaria dictará las normas para la actualización del valor de los bienes y la implementación del impuesto a los grandes patrimonios dentro de los 60 días siguientes a la entrada en vigencia de esta Ley. Esto conlleva la preparación y actualización del valor de todos los bienes de los sujetos pasivos.
  1. Se recomienda preparar hojas de trabajo donde se discriminen los activos por tipo, considerando una amplia descripción de los mismos, ubicación dentro de la empresa, valor histórico, valor ajustado por inflación fiscal, valor según VEN-NIF y valores de avalúo, así como sus correspondientes depreciaciones o amortizaciones, si proceden.
  1. La alícuota impositiva estará comprendida entre el 0,25% y el 1,50% del valor del patrimonio neto. El Ejecutivo Nacional podrá establecer tarifas progresivas conforme al valor patrimonial. Desde la entrada en vigencia de esta Ley y hasta tanto el Ejecutivo Nacional establezca alícuotas distintas, será del 0,25%.
  1. El impuesto se causará anualmente sobre el valor del patrimonio neto al 30 de septiembre de cada año. Se considera concluido el período de imposición cuando:
  • Se produzca la muerte del contribuyente.
  • Se extinga la persona jurídica o la entidad sin personalidad jurídica.
  • La persona o entidad sin personalidad jurídica, cambie su residencia al extranjero.
  • Cuando se produzca la transformación de la forma jurídica del contribuyente
  1. Las entidades públicas o privadas ante las cuales se registren, inscriban o depositen bienes muebles e inmuebles, deberán remitir a la Administración Tributaria la información que esta requiera acerca de dichos bienes.

16. El impuesto sobre el Patrimonio no es deducible del Impuesto Sobre la Renta (ISLR).

17. Los sujetos especiales declararán el valor patrimonial del que dispongan para el momento de la primera declaración (30 de septiembre de 2019), considerando las pautas de valoración básicas establecidas en la propia Ley y las emanadas del SENIAT.

Debemos estar muy atentos a las instrucciones emanadas del SENIAT con respecto a este tributo. Por los momentos, aconsejo implementar la cédula comentada en el punto 12, la cual será de gran ayuda a la hora de realizar los cálculos para este impuesto. Como es habitual, los mantendremos informados de cualquier información adicional que pueda surgir.

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