Doctrina, Revista 81

Inscripción en los RRSS Automotores de los areneros y/o UTV

La realización de este trabajo es intentar unificar criterios, en los Registros Seccionales con competencia Automotor, en cuanto a la exención que conllevan estos vehículos automotores, acorde a su Certificado de Fabricación (llamados cuatriciclos carrozados, areneros, UTV, etc.), respecto al pago del Impuesto al Automotor, como también lograr algún norte por parte de la Agencia de Recaudación de la Provincia de Buenos Aires (ARBA) para que repita de oficio a los usuarios de nuestro sistema registral el tributo mal ingresado en sus arcas acerca de estos areneros y UTV que se deben registrar en dichos Seccionales. Esta problemática que nos atañe, se debe a no haber recibido oportunamente normativa al efecto y/o, en la mayoría de los casos, por haber ingresado éstos al país con anterioridad a norma aclaratoria acerca de su alta impositiva o no al Sistema G2.
Es fundamental adelantar el papel primordial que jugara la Licencia de Configuración de Modelo (LCM) en esta temática a desarrollar desde lo tributario.
Es decir, cómo su registración incide plenamente en una tributación exenta del Impuesto Automotor ante la prohibición de circular en la vía pública, debido a su carencia de LCM.
Es necesario hacer una breve mención de estas unidades en cuestión. De los ya conocidos e inscriptos en los Registros de competencia exclusiva de Motovehículos, denominados Quad/ATV (all terrain vehicles), y sin profundizar en sus características, podemos establecer que éstos están más orientados a una función deportiva y de ocio.
El avance tecnológico en este tipo de mercados hizo que deriven de estos ATV las siguientes categorías, las cuales han de ingresar inmediatamente bajo la órbita con competencia exclusiva de los Registros del Automotor, los cuales son:

• UTV (utility task vehicle, vehículo utilitario para tareas/trabajo), también llamados Rangers en algunos de sus modelos, enfocados principalmente a tareas laborales.
• RUV (recreational utility vehicle, vehículo utilitario recreacional), son similares a los UTV pero tienen un enfoque más deportivo (casi parecen buggies).

Éstos surgieron como una evolución para poder recorrer sobre cuatro ruedas todo tipo de terrenos como su nombre indica.

Ambos (UTV y RUV) son similares a los Quads/ATV, pero tienen ciertas diferencias respecto a ellos; por ejemplo:

– Las dos plazas del vehículo son una al lado de otra (aunque existen modelos de 4 plazas, e incluso de 6 plazas como el polaris ranger crew), lo que se denomina side by side (SxS o SXS).

– Tienen un volante como los buggies o los coches en lugar del manillar más propio de las motocicletas o los motovehículos ATV.

– Tienen arcos antivuelco.

– Disponen de una caja de carga basculante.

Como ya adelantamos, es necesario adentrarse aquí respecto de la normativa en cuanto a la Licencia de Configuración de modelo (LCM) para este caso en concreto. Es así que el Art. 28 de la Ley 24.449, Título V, Cap. I, y su Decreto Reglamentario 779/95, establecen que: Todo vehículo que se fabrique en el país o se importe para poder ser librado al tránsito público debe cumplir las condiciones de seguridad, activas y pasivas, de emisión de contaminantes y demás requerimientos conforme a determinadas especificaciones, para lo cual deberá tramitar la Licencia de Configuración de Modelo (LCM) en la Secretaría de Industria, donde también se tramitan las Constancias Técnicas (CT); caso contrario, el no lograr obtenerla hace que no podrá circular dicha unidad por la vía pública.

Al ser el destino su comercialización se deberá acompañar declaración jurada del compromiso de informar a los usuarios que los vehículos no son aptos para circular por la vía pública (según Ley 24.240 – Defensa del consumidor); y la nota de comunicación al usuario (según Artículo Nº 19 de la Resolución 100/83 – Lealtad comercial). De ser el destino para uso propio, deberá acompañar el compromiso de no utilizarlo en la vía pública.
En la Dirección Nacional de Industria (Sector Automotriz y Negociaciones Industriales) es donde se deberá tramitar la homologación y emisión de la Licencia para Configuración de Modelo (LCM). Este certificado es un requisito necesario para todo vehículo que circule por la vía pública y se otorga para aquellos que cumplan los requerimientos previstos en la Ley Nº 24.449 y su reglamentación. También se emiten las Constancias Técnicas (C.T.) a que hace referencia el Artículo 4º de la Resolución SIC y PyME, Nº 276/06.
Luego de esta aclaratoria se puede, al menos, enunciar que este tipo de vehículo carece de encuadre legal alguno en la posibilidad de poder circular por la vía pública.
Por ende, cuando comenzaron a ingresar al país, a fines de 2008, y con sus inscripciones registrales (patentamiento, alta impositiva y consecuente cobro de impuesto al automotor) trajo inmediatamente aparejado las quejas de varios contribuyentes ante ARBA peticionando la exención impositiva, manifestando -entre otras cuestiones en la gran mayoría de los casos- que si su unidad no puede circular por la vía pública tampoco se emite Cédula de Identificación ni se entregan las chapas metálicas, pues quedan en el Legajo “B”; si sólo se entrega su Cartular ¿cómo puede ser posible que tengan que abonar el Impuesto al Automotor?
La respuesta de esta temática no se hizo esperar tanto de ARBA, a través de su Informe Nº 36/2011, Impuestos a los Automotores-Cuatriciclos Carrozados; al igual que la Circular D.R de la DNRPA Nº 000028 del 30/08/2011, a las cuales llegamos mediante este trabajo de búsqueda investigativa.
Quedan normadas las siguientes cuestiones: Informe de ARBA Nº 36/11, dicha exención recae en los cuatriciclos del caso que no son aptos para ser librados al tránsito público; ello surge del Certificado de Importación. En tal orden de razonamiento, a la Ley 24.449 (Ley Nacional de Tránsito) adhirió la Provincia de Buenos Aires (Ley 13.927), estableciendo que dichos vehículos que se fabriquen o no el país deben contar con una “Licencia de Configuración de Modelo”. Los considerandos de la Resolución Nº 108/2003 de la Secretaría de Industria, Comercio y Minería de la Nación expresa que estos automotores quedan exceptuados de dicha Licencia de Configuración de Modelo (LCM); y la Circular Nº 000028/11 de la DNRPA en el Marco del Convenio de Complementación de Servicios, suscripto oportunamente entre la DNRPA y el Ministerio de Economía de la Provincia de Buenos Aires, el cual informa que acorde al Informe Nº 36.711 de ARBA, los Cuatriciclos Carrozados (o no) no tributan el Impuesto a los Automotores. Por ende, no deberá registrarse en el Sistema de Gercydas y tampoco se deberá realizar retención alguna en concepto del impuesto mencionado.

Como colofón, en lo hasta aquí vertido estamos en condiciones de afirmar que cuando se patentan estos vehículos, el cobro tanto de la parte arancelaria como del sellado tiene mismo tratamiento que un vehículo normal a excepción de la no emisión de cédulas de identificación. Es importante destacar al momento de cargar el dominio y los datos del contribuyente que en el Sistema G2 se deberá exceptuar de dar el Alta Impositiva para no generar el Impuesto al Automotor debido a su exención. En el caso de inscripción de transferencia, su tratamiento es igual al mencionado para el caso de patentamiento, y deberá abonar el sellado correspondiente.
En caso de que el mismo esté inscripto en el Impuesto Automotor deberá solicitarse al Centro de Servicios de ARBA más cercano, la Baja del Impuesto y/o dándole aviso al usuario en el Seccional que deberá concurrir ante la Agencia de Recaudación de la Provincia de Buenos Aires (ARBA).

Bibliografía:

– ARBA Impuestos a los Automotores-Cuatriciclos Carrozados Informe 36/11.
-DNRPA, Circular D.R. Nº 000028 del 30/08/2011.
– arba.gov.ar
– https://silverfenix7.wordpress.com
– www.motologias.es
– www.industria.gob.ar

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