EFECTOS DE LA REFORMA FISCAL 2010 EN EL IMPUESTO SOBRE LA RENTA DE LAS PERSONAS MORALES DEL REGIMEN GENERAL DE LEY QUE CONSOLIDAN FISCALMENTE

Abstract

With the approval of the reform for 2010 which amends the tax consolidation regime, setting a limit of five years before companies begin to pay income tax to be deferred in previous years with this, in each of the first two years of consolidated companies will settle 25% of the tax debt, the third 20% and the fourth the fifth year 15% It is considered that the reform recently approved by Congress is contrary to the origin and purpose of the tax consolidation regime, as it seeks companies that are authorized to determine its consolidated taxable income, pay the tax as if they had not counted with such authorization and, therefore, as if they were individual companies, which are not part of a business group. With the reform approved eliminating the effect of neutral fiscal consolidation groups, a situation that seriously affects the companies that chose to organize that way.