Our experience suggests that individuals tend to disagree with tax authorities about how provisions of international law should be applied. There is often disagreement over which country’s tax law is applicable and to what extent. A dispute usually arises in the case of a cross-border transaction, i.e. if income is earned abroad. This article explores a few steps that will help you analyse the applicable law and find out whether your foreign-source income is subject to Latvian personal income tax (PIT).
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Ask questionLatvian companies often approach foreign organisations or individuals to draw on their expertise and receive advice on matters that are crucial for the Latvian company’s growth. This assistance is best received from a group company in the form of management services or consulting services but the Latvian company may have to hire an unrelated foreign company or personal consultant. This article explores Latvian tax implications (including for the Latvian company) and how to tell whether it is personal income tax (“PIT”) or corporate income tax (“CIT”) that is chargeable primarily.
If an individual is considered to be tax resident simultaneously in two treaty countries (e.g. Latvia and Lithuania) according to their national law, the dispute over the person’s tax resident status will be resolved by treaty article 4(4), which provides for consecutively assessing the following criteria:
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