Hace tiempo que la ley tributaria dejó de hablarle a los ciudadanos

Por Marco Vega López, Abogado y profesor de Derecho Tributario, Decano de la Facultad de Derecho
Universidad de las Américas UDLA.
 
Las normas tributarias siempre fueron de las primeras que los países soberanos se dieron para proteger a sus ciudadanos de la arbitrariedad y el poder del Estado. No es de extrañar, entonces, que los procesos independentistas fueran relacionados, cuando no “detonados”, por los abusos tributarios del monarca a sus súbditos o sus colonias.
 
Pero el poder tributario es tan grande y sus efectos en la vida de las personas tan significativo que había que evitar que las nuevas repúblicas cometieran esos mismos errores, era necesario limitarlo.
 
El principio de separación de poderes, la codificación y el desarrollo de las diferentes cartas fundamentales con sus principios constitucionales, permitieron contener efectivamente ese peligro. Para ello, las normas debían ser claras, estables y justas, para que pudieran realmente ser internalizadas por la población e informar al ciudadano las consecuencias impositivas de sus actos, y éste, en su libertad (si aún creemos que la tiene) desarrollar sus iniciativas y escoger los caminos legales que mejor cumplieran sus objetivos, siendo responsable de los efectos tributarios de sus actos.
 
Nada queda de esa dialéctica en nuestro sistema, múltiples cambios de dirección en la política fiscal han impulsado constantes reformas de los últimos años; pro-recaudación, pro-crecimiento, pro-redistribución, pro-simplificación, pro-modernización, pro-inversión, decantando en un conjunto de normas, no un “sistema”, caótico y estéril para cada una de esas consignas. Un país que recauda menos de lo prometido, que crece menos, que elude más, que invierte menos, que redistribuye peor, con normas más complejas y lejos de la modernidad en materia impositiva (importando ahora impuestos patrimoniales “excepcionales” ya en retirada en gran parte del mundo). 
 
La ausencia de resultados se atribuye rápidamente a una suerte de trabajo inconcluso, y se vuelve a convocar a los autores de esas reformas, una y otra vez, con la esperanza de encontrar la norma que faltó cambiar para producir, al fin, el efecto virtuoso prometido, y que no termina de llegar.
 
Sería deseable volver la mirada hacia un sistema tributario pro-contribuyente, pro-ciudadanos, más justo y eficiente, pero no solo en recaudar, eficiente en ser un instrumento para lograr los objetivos que nos tracemos como sociedad y como individuos sujetos de derecho. Sobre todo, entendible, estable, comprensible para el destinatario, ese es el único camino que lleva a la seguridad jurídica y a la consecuente sensación de justicia, indispensable para su legitimidad y cumplimiento. Mucho me temo que este es el déficit real, la falta de claridad en la dirección y no en la técnica, en el destino que queremos alcanzar con los permanentes cambios.
 
Lamentablemente, la ausencia de diversidad en la mirada del fenómeno tributario, que ha sido la tónica en las últimas décadas, y que se repite en la nueva comisión tributaria convocada por Hacienda (integrada por 16 economistas), no da espacio para suponer grandes avances en este sentido. Por el bien de lo que va quedando del Derecho Tributario, realmente espero equivocarme.
 
 

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