By decision of Parliament Speaker I. Murniece, the double tax treaty (DTT) and its protocol have been suspended indefinitely from 16 May. The decision makes unavailable from this date the DTT and national reliefs that provided for an exemption on the basis that Russia had a DTT with Latvia. In this article we explore how this decision affects paying taxes. And we note that the Latvia-Russia social security agreement is still in force.

This article explores the tax treatment of winnings in prize draws run by social networks and of payments to digital content creators.

We have written before about significant differences in measuring total transactions made with related parties during the financial year, to be reported on line 6.5.1 of the corporate income tax (CIT) return, and controlled transactions that determine whether the taxpayer becomes liable to prepare and file transfer pricing (TP) documentation with the State Revenue Service (SRS).

For many years, challenging the receipt of intragroup services and commercial benefits has been among the most popular grounds for corporate income tax (CIT) assessments made by the State Revenue Service (SRS). Our analysis of one of the latest publicly available transfer pricing court cases leads to the conclusion that such a taxpayer dispute with the SRS has not lost its relevance. This article looks at an example from the Latvian court case – the taxpayer’s dispute with the SRS over missing evidence that the taxpayer has actually received management services from a related foreign company.

We have written before about the statutory personal income tax (PIT) scheme for income from investment accounts effective from 1 January 2018. We have looked at steps the account owner – an individual – must take to qualify for the tax-favoured treatment. This article explores a letter from the State Revenue Service (SRS) explaining whether a non-Latvian tax resident earning income from dealings in financial instruments is eligible for the investment account scheme.

A foreign company planning to do business in Latvia can choose between registering a subsidiary or operating through a branch. This choice is commonly dictated by the group’s governance strategy and long-term plans in Latvia. A foreign company going for a simplified arrangement can register either a branch with the Enterprise Registry or a permanent establishment (PE) with the State Revenue Service (SRS) only for paying Latvian corporate income tax (CIT). This article outlines some CIT and accounting issues relevant to PE activities in Latvia.

Since war broke out in Ukraine, many people have been eager to help Ukrainian people with various donations. Last week we wrote about the Latvian VAT treatment of donations and how the tax rules should be changed to cover various cases. This article explores the corporate income tax (CIT) treatment of donations.

As the war in Ukraine goes on, many companies have unselfishly donated to Ukrainian residents and to Ukrainian refugees having crossed the EU border. Does the current tax regime encourage donations? And how has the Latvian government responded to the present situation?

This article completes what we wrote last week.

When it comes to applying the corporate income tax (CIT) provisions for penalties and donations in practice, we have to deal with the terms “state institution,” “government-funded establishment” and “state-owned company,” which are not defined in the CIT Act or in the rules explaining its application. In this article we explain these terms for CIT purposes.

The Corporate Income Tax (CIT) Act has been recently amended to bring in a new element of the tax base arising from hybrid mismatches. This article explains what hybrid mismatches are and how we identify them.

A company’s shareholders in a general meeting may decide to pay a dividend once the annual accounts showing a profit have been approved. If the company’s articles of association provide for this, the Commerce Act permits an interim dividend to be declared and paid halfway through the financial year. This article explores the legislation and corporate income tax (CIT) treatment of dividends a Latvian branch pays to its foreign head office.

Just before Christmas, the OECD published the long-awaited Global Anti-Base Erosion (GloBE) rules. This article highlights the main principles underlying the system and how the tax liability is computed.
 

The Corporate Income Tax (CIT) Act has been amended only slightly during 2021, as we wrote in our Flash News edition of 20 April 2021. This article explores the latest changes to the CIT Act as well as amendments being proposed for the near future, including the long-awaited rules for bad debt provisions under IFRS 9 Financial Instruments.
 

We have already commented on the corporate income tax (CIT) treatment of flow-through dividends and looked at personal income tax (PIT) relief available to an individual receiving a dividend. This article explores potential pitfalls in the tax treatment of flow-through dividends if a change of shareholder takes place shortly before the company decides to distribute a profit.