Many multinational enterprises have suffered losses from a drop in demand, a supply chain delay or extraordinary operating costs during the period of Covid-19 restrictions. The allocation of such losses and extraordinary costs between related companies is likely to attract the tax authority’s scrutiny so these issues require special attention. This article explores the allocation of losses and Covid-19 specific costs in the light of the OECD’s Guidance on the transfer pricing implications of the Covid-19 pandemic.
While some taxpayers may face challenges in applying their advance pricing agreements (“APAs”) with the tax authorities under the economic conditions resulting from the pandemic, all existing APAs and their terms should be respected unless a critical assumption is breached. This article provides an overview of how COVID-19 affects APAs in the light of the OECD’s “Guidance on the transfer pricing implications of the COVID-19 pandemic.”
As we carry on exploring the OECD’s Guidance on the transfer pricing implications of the Covid-19 pandemic (the “Guidance”) this article offers an overview of how government assistance programmes affect transfer pricing analysis.
The unique economic conditions arising from Covid-19 and national restrictions have caused certain difficulties in applying the arm’s length principle for transfer pricing analysis. To pick up where we left off in our article Covid-19: transfer pricing impact, this one explores Guidance on the transfer pricing implications of Covid-19 the OECD published in late 2020.
The amended transfer pricing (“TP”) rules effective from 2018 authorise the State Revenue Service (“SRS”) to penalise taxpayers for TP breaches. This article explores when the SRS can impose a penalty and what procedures are in place to keep it in proportion.
An adverse economic environment poses certain difficulties in maintaining transfer pricing (“TP”) policies. However, a global economic crisis does not cancel the requirement that controlled transactions be arm’s length. Following our article on Covid-19 and financial transactions, this one explores some other implications of the pandemic for TP outcomes and provides suggestions for TP analysis.
On 11 February 2020 the OECD published the final version of its transfer pricing (“TP”) guidelines for financing transactions, a document welcomed also by Latvian taxpayers within multinational enterprise groups, by tax consulting service providers, and by the State Revenue Service. We wrote several articles about the draft guidelines in 2018 so this series of articles will explore some of the changes arising from the final version. We will also look at some global trends and key aspects to be considered in analysing financing transactions according to the OECD recommendations.
For an ever-decreasing number of businesses, financial return remains the top priority. For others, whether driven by investor demand, regulation or the desire to enhance societal value, there is now an expectation that organisations make environmental, social and governance (ESG) issues and sustainability integral to their corporate strategy, philosophy and reporting. Where does your business lie on the spectrum?
If a stock option awarded to an employee does not meet the criteria for the tax favoured treatment and is consequently taxable at vesting, the Latvian employer is liable to report the award for personal income tax (PIT) and national social insurance contributions (NSIC) purposes and ensure taxes are paid.
PwC provides general information about –
1. why tax resident status is important and how it is determined;
2. when you are liable to file a Latvian annual income tax return and when you can do so voluntarily;
3. social security arrangements.