The case was initiated by an information exchange agreement with Argentina, for undeclared bank accounts in Europe. What the regulations say

By iProfessional

27/04/2023 – 07,00hs

The AFIP denounced a taxpayer for having hidden funds abroad, and wanted him to pay taxes for it. These are bank accounts and investment movements, ddetected through information exchange agreements.

The inspection dates back to the information provided by the French administration within the framework of the Convention to avoid double taxation and prevent tax evasion, Referring to bank accounts in financial banking entities in Switzerland, belonging to Argentine taxpayers, not declared. The AFIP detected an account there and understood that they were undeclared funds,

AFIP: bank account abroad and tax collection

By the test produced, the tax court understood that there is no doubt that the money transferred from the hidden account was invested. And that although the amount initially transferred is not identical to the one that was received at the end of the period, the truth is that the money remained in the investment account, reports the Derecho en Zapatillas site.

Faced with it, The tax authorities have not been able to prove the facts to collect the tax provided that (i) the ownership of the discovered account is not denied, (ii) it is proven that the existing money was transferred to an account declared in the same year, and (iii) that its final destination was the investment.

AFIP: bank account abroad and tax collection

AFIP: bank account abroad and tax collection

In other words, from the evidence provided, it is possible to extract the movements of the money from the time it left the hidden account until its consolidation at the end of the period in the destination account, always remaining invested, and then being entered by the taxpayer in their balance sheets and settlements. income tax for the period in question.

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