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Plurinational State of Bolivia " Y}. .EádEL 7,!
•/Zoy ) Time
3 NATIONAL TAXES ■
CITE: SIN/GGSCZ/DF/SVI/VC/00211/2017

POSITION VIEW N° 291779000241

R-0028
„(002c8
Santa Cruz de la Sierra, August 17, 2017 ?3 68e85cgzw*t
Sirs:
and
ENGINEERING AND CONSTRUCTION PIMEXI SRL
NIT:175288024
MANUEL JOSE JUSTINIANO STREET NRO. 47 NEIGHBORHOOD: OLD MACHINE
Present. -

SUBJECT: VERIFICATION ORDER N° 0015OVI17538 OPERATIONAL 2022

As a result of the Internal Verification process, corresponding to verification order No. 0015OVI17538 of operation 2022, carried
out by the officials of this Management, it was detected based on the information in the taxpayer's purchase books and the
information existing in the tax administration systems, in terms of sales reported by suppliers (SIRAT) and dosages of authorized
invoices (GAUSS system), which have not correctly determined taxes in accordance with Law, before the National Tax Service.

For the reasons stated above, the Santa Cruz Large Taxpayers Management of the National Tax Service, in use of its powers
granted by articles 92°, 93°, 95°, 96° and 100° of Law No. 2492 - Tax Code Bolivia (CTB) and related regulatory provisions, has
proceeded to determine its tax obligations related to the Value Added Tax derived from the verification of the tax credit of the
invoices declared by the taxpayer as purchases, detailed in the annex to the verification order ( F - 7520 ), on CERTAIN BASIS
as established in article 43 of Law No. 2492 - CTB '

VERIFIED TAX: Value Added Tax derived from the verification of the tax credit contained in the invoices declared by the
taxpayer that are detailed in the annex attached to F-7520.
VERIFIED PERIODS: JANUARY, FEBRUARY, MARCH, MAY, JUNE, JULY, SEPTEMBER, AND NOVEMBER OF
THE 2013 MANAGEMENT

Facts, acts, data, elements and valuations

On 08/17/2016, legal notification was made to the taxpayer INGENIERIA Y CONSTRUCCION PIMEXI SRL with NIT 175288024,
personally as established in article 84 of Law No. 2492 - CTB, requiring that within the period of five (5) business days, go to
the Supervision Department of the Santa Cruz Large Taxpayer Management to present the following documentation:
■ Affidavits of the observed periods (Form. 200 or 210).
■ Purchase book for the observed periods.
■ Original purchase invoices detailed in the annex to F-7520.

Graco Santa Cruz Management -Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 - www.impuestos.gob.bo
 Plurinational State of Bolivia

•A NATIONAL TAXES
291779000241
Cr
uz
M ■ Document that supports the payment made.
an ■ Other documentation that the assigned Auditor requests during the process to verify the transactions that support
ag the invoices detailed in the annex to F-7520.
e
m Warning you that failure to submit the indicated documentation would be considered a contravention of Article 70 of Law CON
NS
en No. 2492 - CTB and would give rise to the application Initial
of sanctions Incorrect
provided for in Article 162Method of the same Sales Law.
on Description of the
Odal reason ... , Import» N.LT. Supplier LCV Dosed of
t-
Invoice date N• Incorrect DEBUG

S !h
Authorization No., . , Supplier Purchase Concept Observation data in by the Linked to Activity payment to Banking DD.JJ. from observation or Amo
pearly fartua foresee Invoice registration in LCV Information the validation of each of CODE
of the G.NF LCV S.LN. the Supplier
provider the invoices -
Av The taxpayer, RUDDY
until the date
200100285795
of PRESENT
16,405.78
issuance
THE TAXPAYER DID of this Charge
NOT
THE TAX NOTE
THE TAXPAYER
DID NOT SUBMIT
View, has not DOES
presented
NOT
any of the documents
THE TAXPAYER DID
NOT PRESENT THE NOT MOTIONLE
requested
THE TAXPAYER DID in the
* 10/01/2013 271 NOT DOSED THE TAX NOTE NO N/A NOT PRESENT ANY 1,2,3y4 0
. reference order. RIVEROS 4440232013 REQUESTED BY THE TAX
ADMINISTRATION REQUESTED BY
INFORM TAX
REQUESTED BY THE
NOTE PRESENT SS DOCUMENTATION
THE TAXPAYER
TAX TAX TAXPAYER DID
M 2 14/01/2013 1052
ELECTROIND 2001002923452 926.60
THE TAXPAYER DOES
NOT PRESENT THE TAX
THE
DID NOT PRESENT
IN FAVOR OF
ANOTHER
THE
NOT PRESENT THE NOT GREATER THE TAXPAYER DID
THAN THE NOT PRESENT ANY 1,2 and 3
USTRIAL SRI 185472025 NOTE REQUESTED BY DUPLICATE THE TAX NOTE TAXPAYER YEAH TAX NOTE PRESENT N/A 0.0
el Analysis ASSOCIATION carried out on the observed THE
ADMINISTRATION
fiscal notes
TAX REQUESTED BY
THE TAXPAYER
TAX
KETAL
WITH
SA
a
REQUESTED BY THE
TAX TAXPAYER DID
INVOICE DOCUMENTATION

THE TAXPAYER DID NOT THE INFORMED THE

ch 1 3 23/01/2013 1723
TRANSPORTE
R
3001001963
262
6,500.00
158542028
PRESENT THE TAX
REQUESTED BY THE TAX
NOTE DID NOT
NOT ISSUED THE TAX NOTE
SUBMIT WITHOUT
NITDThe
YEAH TAX
NOT PRESENT THE NOT
NOTE PRESENT N/A
GREATER THE TAXPAYER DID
THAN THE NOT PRESENT ANY 1,2y3 0.0

or
INVOICE DOCUMENTATION.
The objective of this review is to verify correct compliance with the Tax Provisions contained in Law No. 843 "Current
ARROW TO ADMINISTRATION REQUESTED BY TAXPAYER REQUESTED BY THE
THE SOUTH THE TAX TAX
SUB-TOTAL JANUARY/2O13 23,832.38
Pi Ordered Text", Supreme Regulatory THE TAXPAYERDecrees
DID NOT and THE Regulatory
TAXPAYER
Resolutions INFORMED of the Board of Directors inGREATER
THE TAXPAYER DID
force, THE related to the
0

DID NOT PRESENT NOT PRESENT THE NOT TAXPAYER DID

nt 4 06/02/2013 319
ECONOMICA 2001002942 14,000.

"Value Added Tax" (VAT). ), which

SRL 446 00
¡83766029
PRESENT THE TAX NOTE
REQUESTED BY THE TAX
NOT ISSUED THE TAX NOTE
includes the REQUESTED verification BY of the
WITHOUT

tax
NITDEL
credit
YEAH TAX
contained
NOTE PRESENTE
REQUESTED BY THE Din the invoices
N/A THAN THE NOT PRESENT ANY 12,1
INVOICE presented
DOCUMENTATION. and 0
ADMINISTRATION TAXPAYER
o THE TAX
THE TAXPAYER
TAX
THE TAXPAYER DID
declared by the taxpayer recorded in theTAX observation
THE TAXPAYER DID NOT
table
DID NOT PRESENT of the details of
INFORMED differences attached
NOT PRESENT THE NOT to the Form.
GREATER THE 7520.TAXPAYER DID
N° .5 22/02/2013 322
ECONOMICA
SRL
2001002942 14,900.
446 00
183766029
PRESENT THE
REQUESTED BY THE TAX
NOTE
NOT ISSUED THE TAX NOTE
REQUESTED BY
WITHOUT
TAXPAYER NIT
YEAH TAX
REQUESTED BY THE
NOTE PRESENT N/A THAN THE NOT SUBMIT ANY 1,2» 3
INVOICE DOCUMENTATION
0.0
ADMINISTRATION
32 As aSUB-TOTALresult of the procedures
FEBRUARY/2013 28,000.
executed based onTHEthe
THE TAX
information provided by
TAX
the Inspection Management and/or other
00
1- THE TAXPAYER DID NOT TAXPAYER THE TAXPAYER DID
Managements dependent on
2001002736 16,061. 101837502 the
PRESENTNational
THE TAX NOTE Tax Service,
NOT ISSUED THE TAX NOTE within operation
DID NOT PRESENT INFORMED BY
LOWER No. 2022, observations
NOT SUBMIT THE NOT
were
LESS THAN
established
THE TAXPAYER DID
NOT PRESENT ANY 1,2y3 as a
S
14/03/2013 4121 BOLIVIA SRL YEAH TAX NOTE PRESENT N/A
528 64 9 REQUESTED BY THE TAX INVOICE 0
REQUESTED BY AMOUNT REQUESTED BY THE DOCUMENTATION.

an result of comparing
SUB-TOTAL MARCH/2O13
the information
16,061. in
ADMINISTRATION
the Purchase THE TAXBook. of the taxpayer and the
TAX information presented by suppliers in
64

ta their VAT Sales

IMPORTATION
AND
Books through the Da Vinci
THE TAXPAYER DID NOT
7904001117 19,670. 102844502 PRESENT THE
Software (in
THE TAXPAYER
DID NOT PRESENT
application of
NOT
article 7 of Supreme
THE TAXPAYER DID
NOT PRESENT THE NOT Decree 27310
GREATER of 01/09/2004,
TAXPAYER DOES NOT
7
06/05/2013 14050 REPRESENTA TAX NOTE REQUESTED DUPLICATE THE TAX NOTE NO NOTE PRESENTE N/A THAN PRESENT ANY 1,2,34

Cr the information TIONS

ROGHURSA
presented
65 00 3
by suppliers
BY THE
TAX ADMINISTRATION
through their REQUESTED
THE TAX
SalesBY Books VAT INFORMED
through TAX the Da
REQUESTED
TAX
BY THEVinci
D Software BILL have evidentiary
DOCUMENTATION. 0

THE TAXPAYER IN FAVOR OF THE TAXPAYER DID

uz validity), 8
17/05/2013 339
and
RIBERPARidentifying invoices
7904001480 5,000.0 that
101534902 SUBMIT contain
THE TAXPAYER DID NOT
THE TAX NOTE information
DID NOT PRESENTdifferent from
NOT ISSUED THE TAX NOTE
ANOTHER
TAXPAYER
that YEAH declared
NOT PRESENT
TAX
inNOTE the
THE NOT supplier's
PRESENTE N/A
VAT Sales Books
GREATER THE TAXPAYER DID
THAN THE NOT PRESENT ANY 1,2»3
GROUP 50 0 7 REQUESTED BY THE TAX 0
- (amount subject to the 24,670. Tax Credit, issuance date, name,
ADMINISTRATION
REQUESTED BY AI
TAX NIT or CI, among MAMANI WITHothers)
CARMELA
TAX , for which the taxpayer did not present
REQUESTED BY THE D INVOICE DOCUMENTATION

SUB-TOTAL MAY/2013
Te sufficient documentation to demonstrate 00
THE TAXPAYER DID that
NOT their invoicesTHE TAXPAYER are valid for tax credit in
INFORMED
THEthe periods
TAXPAYER DID subjectGREATER to verification. 0

DID NOT PRESENT NOT PRESENT THE NOT THE TAXPAYER DID
l. 9
25/06/2013 333
ECONOMICA 2001002942 26,486.
SRL 446 00
183766029
PRESENT THE TAX NOTE
REQUESTED BY THE TAX
NOT ISSUED THE TAX NOTE
REQUESTED BY
WITHOUT
TAXPAYER NIT
YEAH TAX
REQUESTED BY
NOTE PRESENTE
THE D
N/A THAN THE NOT PRESENT ANY 1.2y3
INVOICE DOCUMENTATION.
0
ADMINISTRATION
Pil
In application of articles 4 and 8 of Law 843 (Ordered THE TAXPAYER DID Text),
NOT article
THE TAX
8 of Supreme Decree
THE TAXPAYER
INFORMED
No. 21530 TAX
THE TAXPAYERandDID other
NOT
regulatory
GREATER
provisions, it is
THE TAXPAYER DID
DID NOT PRESENT NOT PRESENT THE
ot:
established that the taxpayer,
' 10 25/06/2013 334
ECONOMICA 2001002942 26,486.
SRL in
446 order 00 to183766029
PRESENT THE TAX NOTE
benefit
REQUESTED fromBY THEthe
TAX calculation
NOT ISSUED THE TAX NOTE
REQUESTED BY
of the tax credit
WITHOUT
resulting
TAXPAYER NIT
YEAH TAX
from the
REQUESTED BY THE D
transactions
NOTE PRESENTE N/A
he
INVOICE declares, must
THAN THE NOT PRESENT ANY 1,2y3
DOCUMENTATION.
0
ADMINISTRATION
33 the followingSUB-TOTAL
meet requirements:
TOGETHER/2013 52,972.
THE TAX TAX
00 0
34 In03/07/2013
this regard, paragraph 5 102070302
THE TAXPAYER DID NOT
of art.PRESENT
70°THEof Law No. 2492
THE TAXPAYER
DID NOT - CTB establishes,
PRESENT INFORMED
among
THE TAXPAYER DID
others,
NOT PRESENTthat THE NOTit is the tax obligation
GREATER THE TAXPAYER ofDIDthe
146029 2904004933 WITH
41 TAX NOTE REQUESTED DUPLICATE THE TAX NOTE YEAH TAX NOTE PRESENTE N/A THAN THE NOT PRESENT ANY 1,2y3
11
ENTELSA 640.00
1 68 3 DIFFERENT 0
taxable person to "demonstrate the BY THE
origin and amount
TAX ADMINISTRATION THE TAXof the tax credits
REQUESTED BY
that
ISSUE DATE he considers
REQUESTED BY THE D
TAX appropriate"}INVOICE the following
DOCUMENTATION
table
6- ADMINISTRATION
THE TAXPAYER ADMINISTRATION
THE TAXPAYER DID
shows the observations indicated.
FOPTO

THE TAXPAYER DID NOT DID NOT PRESENT NOT PRESENT THE NOT GREATER THE TAXPAYER DID
Fa 12 03/07/2013
146029
1
ENTELSA
2904004933
68
640.00
102070302 SUBMIT THE TAX NOTE
3 REQUESTED BY THE TAX
DUPLICATE THE TAX NOTE
REQUESTED BY
NOT
INFORMED
5! TAX NOTE PRESENTE N/A
REQUESTED BY THE D
THAN
BILL
NOT PRESENT ANY 1.2y3
DOCUMENTATION
0

x:
ADMINISTRATION THE TAX
TAX
THE TAXPAYER ADMINISTRATION
THE TAXPAYER DID
THE TAXPAYER DID NOT
33 ' 09/07/2013 927613
OMAR
CRISPIN
2001002833 9,000.0 239817701 PRESENT THE TAX NOTE
245 0 2 REQUESTED BY THE TAX
DID NOT PRESENT
DUPLICATE THE TAX NOTE
INFORMED IN
FAVOR OF THE YEAH TAX
NOT PRESENT THE NOT
NOTE PRESENTE N/A
GREATER THE TAXPAYER DID
THAN THE NOT PRESENT ANY 1,2,1
0
76 COLQUE REQUESTED BY TAXPAYER REQUESTED BY THE D INVOICE DOCUMENTATION.
ADMINISTRATION THE TAX TAX
ADMINISTRATION
THE TAXPAYER ADMINISTRATION
THE TAXPAYER DID
43 OMAR
THE TAXPAYER DID NOT
2001002833 9,000.0 239817701 PRESENT THE TAX NOTE
DID NOT PRESENT
NOT
NOT PRESENT THE
NOTE NOT
GREATER THE TAXPAYER DID
14 09/07/2013 9276 CRISPIN DUPLICATE THE TAX NOTE YEAH TAX N/A THAN NOT PRESENT ANY 1,2y3 0.0
4- COLQUE
No.
245 0 2 REQUESTED BY THE TAX
Requirements
ADMINISTRATIONDetail
REQUESTED
THE
BY
TAX
INFORMED
Legal Support
REQUESTED BY THE PRESENT
TAX
BILL DOCUMENTATION

w SUBTOTAL JUNE/2013 19,280.00

ADMINISTRATION ADMINISTRATION
Article 4 and 8 of Law 843 and beginning 1) of Article 41 of the RND 0
1 Transaction supported with the original invoice
w
THE TAXPAYER DID NOT THE TAXPAYER
10,0016,07 THE TAXPAYER DID
JULIO CESAR PRESENT THE FISCAL DID NOT PRESENT NOT PRESENT THE NOT GREATER THE TAXPAYER DID
15 7001003250 1,742.50 NOT
30/09/2013 664 TASSEO IOTA REQUESTED BY DUPLICATE THE TAX NOTE YEAH TAX NOTE PRESENTE N/A THAN THE NOT PRESENT ANY l,2y3 0.0
471 4590609012 INFORMED
w. SENSEVE
2 Transaction linked to the taxedTHE activity
ADMINISTRATION
TAX REQUESTED
THE
BY
Article
TAX
8 of Law 843, Arícalo 8 DS 21530 REQUESTED BY THE D
TAX
INVOICE DOCUMENTATION.

im SUB-TOTAL SEPTEMBER/2013 1,74150

Transaction effectively carriedTHE out,TAXPAYER

supported DIDby accounting THE
NOT
Article
TAXPAYER
2 and 4 of Law 843; Article
FAVOR OF THE
36, 37 and 40 of Decree
THE TAXPAYER DID
Law 14379 -
0

DID NOT Commercial Code; mumerals 4 and 5 of the NOT SUBMIT THE NOT
pu 16
10/11/2013 71
3
EDGAR HUGO 2001033338 4,066.00
documents and2019454019
DELGADILLO 630
means of payment PRESENT THE TAX NOTE
REQUESTED BY THE TAX
NOT ISSUED THE TAX NOTE
SUBMIT
Article 70 of Law 2492 -PCS
TAXPAYER
NUEVATEL SA
CTB
YEAH TAX NOTE PRESENT N/A
INVOICE
MEMORIAL
THE TAXPAYER DID
NOT PRESENT ANY l,2y3
0
REQUESTED BY WITH ITT REQUESTED BY THE DOCUMENTATION.
es 4
ADMINISTRATION
Other requirements contemplated in the RND 10.0016. 07
THE TAX 1007173022
Article 41 and 43 RND 10.0016.07
TAX

to
SUB-TOTAL NOVEMBER/2O13 4,066.00
GRAND TOTAL 170.624.S2

s.
go
b.
bo
o Santa Cruz Management - Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 - www.impuestos.gob.bo
Plurinational State of Bolivia

291779000241
 OR)
Plurinational State of Bolivia

= NATIONAL TAXES
•LB 291779000241

The inextensive detail of the observations of each fiscal note is reflected in the work paper that is part of the file,
likewise the codes used are described as follows:

TAX NOTES NOT VALID FOR TAX CREDIT

Code No. 1: Without original invoice support

After verifying the registration of the Tax Notes declared in the VAT Purchase books, the absence of Tax Notes
was evident ( the original invoice has not been presented), failing to comply with the provisions of paragraph 1)
of Paragraph I of article 41 of the RND. 10.0016.07, it being impossible to identify the veracity of the operation,
consequently, it could not be verified whether the purchases are linked to the taxed activity for which the
taxpayer is a taxable person.

Code No. 2: Not linked to the taxed activity.

Since the taxpayer did not present the requested documentation, the connection of the purchases with the
taxable activity of the company could not be evidenced, so it must be observed in application of the provisions
of article 8 or of Law 843, paragraph a). , second paragraph, which establishes that the transactions must be
linked to the taxable activity of the taxpayer, consequently for the invoices not presented in original the link
could not be verified, therefore they have no relationship with the taxable activity of the taxpayer; with the
understanding that "They will only give rise to! computation of! tax credit provided here for definitive purchases,
acquisitions or imports, contracts for works or services or any other benefit or input of any nature, to the extent
that they are linked to the taxed operations, that is, those intended for the activity for which the subject is
responsible for the lien".

According to the taxpayer registry, during the periods subject to verification, the taxpayer records the activity of
ARCHITECTURE AND ENGINEERING ACTIVITIES AND OTHER TECHNICAL ACTIVITIES. Since the
taxpayer does not present the original of the invoice or its supporting documentation, it is not possible to
establish the nature of the expense in order to verify the relationship of the purchase with its taxable activity. In
this regard, the taxpayer must demonstrate that these purchases are intended for the provision of their taxable
activity (through accounting records, order orders, entry into warehouses, inventory Kardex, service contracts
and other documentation) or, where appropriate, demonstrate objective and reasonably that they were
expenses incurred as a result of their own requirements and necessary for the normal development of their
taxed operations.

Consequently, the invoices observed under this observation code do not correspond to be declared for the
purposes of the tax credit as they contravene the provisions of article 8 of Law No. 843 and article 8 of the DS
No. 21530, which establish that only purchases to the extent that they are linked to taxable operations will give
rise to the calculation of tax credit.

Code No. 3: Does not demonstrate the effective completion of the transaction.

By not having presented any documentation to support the purchases declared subject to this verification, it
does not allow us to demonstrate that the transactions have actually been carried out, that is, it could not be
verified that the purchases have been made, that the products have been received and /or services from your
provider and paid for them.

Graco Santa Cruz Management -Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 - www.impuestos.gob.bo
 Plurinational State of Bolivia

291779000241
3 NATIONAL TAXES

In this regard, it should be noted that the appropriation of the tax credit depends on compliance with substantial
and formal requirements that allow establishing the existence of the taxable event and considering them valid
for tax purposes, so, in order to demonstrate the origin and amount of your tax credits, The taxpayer must
provide accounting, commercial and financial documentation that allows to demonstrate with certainty the
payment to the supplier and verify that the purchase-sale operation was real. To this end, it is necessary to
point out that the accounting cycle is an entire process of recording information that culminates with the
issuance of the Financial Statements, which provides general and classified information that can be verified
from the breakdown shown in the Daily Books and Ledgers prepared in turn based on Accounting Receipts
(Journals, Expenses and Income) duly supported with special records, auxiliaries, kardex, inventories, notes of
receipts to warehouse, reports, contracts, forms, requests and others that demonstrate the transfer of the asset
and/or the effective provision of the service; as well as with means of payment to the supplier (receipts, copies
of checks, transfers, debits or others), proof of receipt of payment, bank statements, cash payment assistants,
surrenders of funds, accounting records of payment appropriation and others. documentation that definitively
supports the effective payment to the supplier; Consequently, the taxpayer, in order to demonstrate the veracity
of the facts, must use all this information and documentation; which you are also required to carry, to be
presented as support for your declared transactions.
Numerals 4 and 5 of article 70 (Tax Obligations of the Taxable Subject) of Law No. 2492 - CTB and in turn,
articles 36 and subsequent articles of the Commercial Code, Decree Law No. 14379, establish and indicate the
obligations of taxpayers regarding the documentation they must have and the information that said
documentation must contain. Likewise, article 2 of Law No. 843 states that, for VAT purposes, the sale is
conditional on the occurrence of the requirements of onerousness and transfer of ownership, therefore, in
commercial transactions, both the buyer and the seller, must have sufficient documentation to demonstrate
compliance with both requirements.
In this sense, by virtue of article 76 of Law No. 2492 - CTB which provides that "In administrative and
jurisdictional tax procedures whoever intends to assert his rights must prove the facts constituting them...", in the present
case, being that the taxpayer intended to assert his right to the calculation of the tax credit, is the one who should have
provided sufficient evidence to demonstrate that the transaction was actually carried out, a situation that was not
demonstrated, so the calculation of the VAT tax credit does not correspond to him, consequently, said transactions do not
meet the third requirement.

Code 4.- Not measured by the Tax Administration.

It was evident that the tax notes observed with this code were not dosed by the Tax Administration, according
to the information recorded in the GAUSS module of the Tax Administration System, so they are not valid for
tax credit, in application of numeral 2. ) of article 41 of the R..ND No. 10-0016-07, which establishes as an
essential requirement for the validity of the tax credit that the tax note had been properly dosed by the Tax
Administration.

Determination of Omitted Taxes

The process of determining the tax debt was carried out on a Certain Basis, as established in paragraph I of
article 43 of Law No. 2492 - CTB and article 7 of Supreme Decree 27310, concluding that the taxpayer has not
demonstrated with sustainable documentation that all of

Graco Santa Cruz Management - Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 - www.impuestos.gob.bo
 •R NATIONAL
Plurinational TAXES
State of Bolivia

•R NATIONAL TAXES
291779000241

Boliviano

PERIOD

SETTLE
08/17/20

FISCAL
UPDAT
ED AS
(Expres

MENT
sed in
s and
UFV)

OF

OF
17

S
The observed transactions have been effectively carried out, so the invoices are not valid for the calculation of
the tax credit, consequently their purification is appropriate.
SETTLEMENT DATE: 08/17/2017 UFV: 2.21197 PENALTY FOR NON-PAYMENT: 100%

Once the observations detected in relation to VAT - Tax Credit were consolidated, differences were determined
in favor of the Treasury for purchases not valid for tax credit of Bs170,625.- (ONE HUNDRED AND SEVENTY
THOUSAND SIX HUNDRED AND TWENTY-FIVE 00/100 Bolivianos) which causes the omission of the Tax
Added Value (VAT) - Tax Credit of Bs22,181.- (TWENTY THOUSAND ONE HUNDRED AND EIGHTY ONE
00/100 Bolivianos), according to the following detail:

DETAILS OF AMOUNTS OBSERVED VAT

(Expressed in Bs)
TOTAL
TOTAL 1-
TOTAL IM PC ' = IM DEBUGATED
PERIOD AMOUNT CERTAIN
OBSERVED PORTE -
DOWNLOADED VAT
BASE
TO b c D =(BC) E = D x 13%

Jan-13 23,832 0 23,832 3,098

Feb-13 28,000 0 28,000 3,640

The interest applied corresponds to the calculation of: 4% annually from the day following the expiration of the term until the last day of the fourth year and 6% annually from the first day of the
fifth year until the day of settlement,
Mar-13as established in paragraph I16,062
of art. , 47° of Law 2492, modified
0 by Art, 2 of Law 16,062
812. 2,088

May-13 24,670 0 24,670 3,207

The tax debt was calculated from the day following the due date of the omitted tax until the date of issuance of
this document, inJun-13
accordance with the52,972 0
provisions of article 52,972
47 of Law 6,886
NO 2492 - CTB, modified by Article 2 of
Law N ° 812 of June
Jul-1330, 2016. 19,280 0 19,280 2,506

Sep-13 1,743 0 1,743 227

Act or omissionNov-13
that constitutes
4,066
evidence of tax illegalities
0 4,066 529

TOTALS 170,625 0 170,625 2 2,181

The actions and omissions attributable to the taxpayer are the following:

Prior settlement of the Tax Debt

SUBCONCEPT TABLE AND LEGAL BASIS OF THE CHARGES_________________________________
ZJ CONCEPT- i ......................................... . LEGAL SUPPORT
In accordance with the provisions of paragraph I of article 96 and paragraph IV of article 104 of the Law / No.
OBSERVATION
2492 - CTB and pertinent legal provisions, by virtue of the tax verification process - carried out and considering the
objections determined in favor of the Treasury in the Value Added Tax (VAT), the Tax Administration proceeded to
Law No. 843
a Certain
calculate the Tax Debt on Art. Basis, as established in paragraph I of article 43 of Law NO 2492 - CTB,
8 or a) The amount resulting from applying the rate established in Article 15 to the amount of purchases,
applying the provisions of article
definitive47 of the
imports samecontracts
of goods, legal body, modified
for works by or
or services, paragraph I of article
any other benefit or input2covered
of Law by No. 812,
the tax, that
determining a Tax Debt of UFVs29,
they had been (TWENTY-
431invoiced NINE
or charged THOUSAND
through FOUR HUNDRED
equivalent documentation in the fiscalTHIRTY-ONE
period being settled. (...).
Housing Development Units) equivalent to Bs65,103 (SIXTY-FIVE THOUSAND ONE HUNDRED THREE 9*
Code 1 : Regulatory Resolution of the Board of Directors No. 10-0016-07
00/100 Bolivianos), which
1 Without includes
support of the Updated Omitted Tax, Interest, Penalty for Non-Payment and LE.. Fines for non-
compliance with
the original formal
invoice duties,
Art. in accordance
41° (Validity with or
of fiscal notes articles 165° and
fiscal notes).- 169°
I. The fiscalofnotes,
Lawfiscal
NO notes
2492or-equivalent
CTB, according
documentsto
will
the following detail: generate tax credit for taxpayers of VAT, RC-IVA (dependent and direct taxpayer), IUE (liberal professions and
trades) and STI, in the terms provided in Law No. 843 (Current Ordered Text) and regulatory Supreme Decrees,
provided they contain or meet the following requirements: 1) It is the original of the document. (...).
 Plurinational State of Bolivia

291779000241
Law No. 843
Art. 8 o .- From the tax determined by application of the provisions of the previous article, those responsible will
subtract: "a) The amount resulting from applying the rate established in Article 15 to the amount of purchases,
definitive imports of goods, works contracts or contracts for the provision of services, or any other benefit or input
covered by the lien, which had been invoiced or charged through equivalent documentation in the fiscal period
being settled... Only definitive purchases, acquisitions or imports, contracts for works or services, or any other
provision or input of any nature will give rise to the calculation of the tax credit provided for herein, to the extent that
they are linked to the taxable operations, that is, those intended for the activity for which the subject is responsible
Code 2 ; for the lien."
2 Not linked to the
taxed activity D.S. N° 21530 - Value Added Tax Regulations

Art. 8°.- "The computable tax credit referred to in Art. 8 or

paragraph a) of Law No. 843 "Current Ordered Text", is
that originated in purchases, acquisitions, contracts or definitive imports reached by the tax linked to the activity
subject to the tax... For the purposes of determining the tax credit referred to in the previous paragraph, taxpayers
will apply the rate established in Article 15 of Law No. 843 "Current Ordered Text" to the invoiced amount of their
purchases; definitive imports of goods, works contracts or provision of services, or any other provision or input
covered by the tax..."

Law No. 843

Art. 2.- For the purposes of this Law, any transfer for consideration that involves the transfer of ownership of
movable things is considered a sale (sale, exchange, dación en pago, expropriation, adjudication by dissolution, of
companies and any other act that leads to the same end). (...).
Art. 13°.- The regulations will establish the rules to which the form of issuing invoices, fiscal notes or equivalent
documents must be adjusted, as well as the records that those responsible must keep.

Law No. 2492 - Bolivian Tax Code

Art. 70.- (Tax Obligations of the Taxable Subject). They constitute tax obligations of the taxpayer: 4. Support
taxed activities and operations, through books, general and special records, fiscal notes, tax notes, as well as other
documents and/or public instruments, as established in the respective regulatory provisions. 5. Demonstrate the
origin and amount of the tax credits that you consider appropriate (...).

Code 3 : Lev Decree No. 14379 - Commercial Code

It does not Art. 36.- (Obligation to keep accounting) Every merchant is obliged to keep accounting appropriate to the nature,
3 demonstrate the importance and organization of the company, on a uniform basis that allows demonstrating the situation of their
effective completion businesses and a clear justification of all and each of the acts and operations subject to accounting, and must also
of the transaction keep the books, documents and correspondence that support them in good condition.
Art. 37.- The merchant must necessarily keep the following books: Journal, Ledger, Inventory and Balance
Sheets, unless other books are specifically required by law. You may also keep those books and records that you
deem appropriate to achieve greater order and clarity, obtain information and exercise control (...).
Art. 40.- Merchants will present the books that they must carry, bound and numbered, to a Public Notary so that,
before using them, they include, in the first page of each one, a record of the application that will be given to them.
with indication of the name of the person to whom it belongs and the number of pages it contains, dated and
signed by the intervening Notary, also stamping, on all pages, the seal of the notary that authorizes it and
complying with the established tax requirements (. ..) Art. 44.- In the Journal book, the operations carried out by
the company will be recorded day by day and in progressive order, in such a way that each item clearly expresses
the debtor and creditor account or accounts, with a clear and precise gloss of such operations and their amounts,
with indication of the people involved and the documents that support them. (...).

Grace Santa Cruz Management -Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 - www.impuestos.gob.bo

Graco Santa Cruz Management - Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 - www.impuestos.gob.bo
Plurinational State of Bolivia

291779000241
 Plurinational State of Bolivia

•A NATIONAL TAXES
291779000241

Supreme Decree No. 27310 Regulations to the Bolivian Tax Code

Art. 7.- Electronic operations carried out and recorded in the Tax Administration's computer system by an
authorized user have legal effects, the information generated, sent, received, stored or communicated through
computer systems or electronic means, by any authorized user who how an electronic record resulted, has
evidentiary validity.

Law No. 843

Art. 13°.- The regulations will establish the rules to which the form of issuing invoices, fiscal notes or equivalent
documents must be adjusted, as well as the records that those responsible must keep.
Regulatory Resolution of the Board of Directors 10-0016-07
Code 4:
4 Art. 41° (Validity of fiscal notes or fiscal notes).- paragraph I. Invoices, fiscal notes or equivalent documents
Not dosed
will generate tax credit for VAT taxpayers..., in the terms provided in Law No. 843 (Ordered Text in Force) and
Supreme Regulatory Decrees as long as it meets the following requirements: 2) Have been duly dosed by the Tax
Administration, recording the tax identification number of the issuing taxpayer, the invoice number and the
authorization number.

Fines for failure to comply with formal duties

On 07/28/2017 , the Act for Tax Contravention Linked to the Determination Procedure No. 157859 was issued to the
taxpayer, due to the failure to present the requested documentation, conduct that contravenes the provisions of article 70 of
Law NO 2492. - CTB, sanctioned as established in sub-numeral 4.1 of Annex I of the RND 10-0032-15, with a fine of 3,000
UFV's (THREE THOUSAND Housing Promotion Units).
DETAIL OF THE NON-COMPLIANCE WITH THE FORMAL DUTY
RULE RULE
N MINUTES l*> DATE PERIOD
UNFULFILLED FORMAL DUTY UFV AMOUNT INFRINGED DORA SANCTIONS
Failure to deliver documentation and
information required by the Tax
Administration during the execution of Article 70 of Law
RND. 10.0032.15 subsection
1 157859 28/07/2017 08/2016 inspection, verification, control and 3,000 2492 Bolivian Tax
4.1 Section 4 of Annex I
investigation procedures, within the Code
established deadlines, means and
places
TOTAL IN UFV's 3,000

The verification and control of compliance with formal duties was carried out by virtue of the unification of procedures
established in paragraph I of Article 169 of Law No. 2492 - CTB and paragraph d) of article 29 of Supreme Decree No.
27310.

Preliminary qualification of conduct

Therefore, the actions and omissions detailed above constitute indications of Omission of Payment, such conduct being
sanctioned with 100% (one hundred percent) of the Updated Omitted Tax, in accordance with article 165 of Law No. 2492 -
CTB and article 42° of Supreme Decree No. 27310, modified by paragraph IX of article 2 of the DS No. 2993 dated
11/23/2016.

This determination enjoys the principle of legitimacy, in accordance with article 65 of Law N 2492 - CTB, with the burden of
proof being transferred to the taxpayer, so that he can present and

Graco Santa Cruz Management -Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 - www.impuestos.gob.bo
 Plurinational State of Bolivia

291779000241
3 NATIONAL TAXES

demonstrate exculpatory evidence of the results of this process, within the framework of article 81 of the
aforementioned legal body.

At the same time, you are informed that the Internal Verification carried out includes only the aspects defined
herein, which does not limit the power of the Tax Administration to exercise future audits on the same taxes
and periods settled in accordance with article 66. of the Tax Code (Law 2492). Whose documentation and
action report is at your disposal in the Supervision Department of this Management, until the issuance of the
Determinative Resolution.

Reduction of sanctions

For the purposes of payment, it should be noted that according to article 2, paragraph V of Law No. 812, which
modifies article 157 (Effective Repentance) of Law No. 2492 - CTB, the penalty for non-payment will be
automatically extinguished. with payment of the entire debt, within ten (10) days of notification of this Charge
View.

Likewise, the taxpayer may enjoy the benefits granted by article 156 (Reduction of penalties) of Law No. 2492
- CTB, modified by article 2, paragraph IV of Law No. 812, and the provisions established in the article 2 or
{MODIFICATIONS) of the DS No. 2993 dated 11/23/2016, according to the following table:

The payment of the Tax Debt after the tenth day of the notification with the Charge Hearing and until before the
80%
notification with the Determinative Resolution.
The payment of the Tax Debt after the Determinative Resolution has been notified and until before the
60%
presentation of the Appeal Appeal before the Regional Tax Challenge Authority.
The payment of the Tax Debt after the filing of the Appeal Appeal and before the presentation of the Hierarchical
40%
Appeal before the General Authority for Tax Challenges.
■% REDUCTION
PENALTY PAYMENT REDUCTION CHART SANCTION

The reduction of the penalty will be given as long as the omitted tax and interest corresponding
to the payment date are paid, and the percentage reduction will be applied to the amount of the omitted tax
updated in UFVs, by tax and/or period pending payment. upon the expiration of the tenth day after notification
of the Charge Hearing. The reduction of penalties is also applicable if the taxpayer establishes payment
facilities for the tax debt, as established in article 38 of the DS. 27310, modified by paragraph VII of article 2 or
(MODIFICATIONS) of the DS 2993 of 11/23/2016.

MEFISAN Deadline and place to present defenses

TO " ._____________________________-________
(SCR 11 Having detailed the concept of the charge and the tax per period, if it does not merit an objection
, to the observations contained in this Charge View, it will be helpful to agree to the amount
determined in favor of the Treasury, placing the amount of the tax debt updated on the date of payment, plus
the sanction for their conduct and fines for breaches of formal duties if applicable, in accordance with articles
47 and 156 of Law No. 2492 - CTB, modified by article 2, paragraphs I and IV, of Law No. 812 and article 169°
of the Tax Code.

If objection is merited to the objections initially formulated by the verification carried out and as
provided by the first paragraph of article 98 of Law N 2492 - CTB, the taxpayer has

Graco Santa Cruz Management - Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 - www.impuestos.gob.bo
 Yo
Plurinational State of Bolivia

•R NATIONAL TAXES 291779000241

a period of thirty (30) days to formulate and present the defenses that you deem appropriate, at the offices ;
the Management of Large Contribuyentes Santa Cruz, located at Avenida Melchor Pinto N° 321.

Once the established period has expired, in accordance with the provisions of article 99 of Law N 2492 - CTB,
following a Report of Conclusions regarding the evaluation of the discharges, their absence or the documented
payment of the total amount in favor of the treasury. determined, the Tax Administration will issue a
Determinative Resolution, to conclude or, where appropriate, continue with the procedures established to

Graco Santa Cruz Management ~Av. Melchor Pinto N° 321 - Santa Cruz - Tel. Pilot: 3334416 - Fax: 3376434 -
www.impuestos.gob.bo
291779000241