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.
We have spent the last year or so coming to terms with the Covid-19 pandemic, which has changed our daily lives beyond recognition. While we keep thinking mainly about the restrictions and outbreak statistics, it would be useful to figure out whether companies are now subject to a heightened risk of money laundering and terrorism and proliferation financing (“ML/TPF”) and whether the internal control systems set up by persons subject to the Anti Money Laundering and Counter Terrorism and Proliferation Financing Act are still as effective as they were before the 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.”
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.
Travel restrictions due to Covid-19 are affecting not only our plans to relax abroad but also trips we take for business purposes. For some workers this means having their regular business trips cancelled and spending more time videoconferencing, while others have their normal place of work changed. We can work from home for foreign as well as local companies. This article explores some aspects of employment income taxation for employees physically working abroad because of pandemic-related restrictions.
Given the impact of Covid-19 on many companies, on 14 July the Cabinet of Ministers adopted regulations to allocate EUR 19.2 million in aid to companies in the tourism industry and EUR 51 million in aid to exporters whose financial position has significantly deteriorated as a result of Covid-19. The new rules will come into force on the effective date of the European Commission’s decision on the compatibility of business aid with the EU internal market. This aid will be administered by the Latvian Investment and Development Agency, awarding it within the available finance allocation and by reference to the sequence in which aid requests are submitted. The aid will take the form of a grant aimed at helping companies pay wages and salaries.
Although the global economy is undergoing significant transformation as a result of Covid-19, capital keeps moving across borders and investors are still interested in investing. In these uncertain times, investors are particularly keen to maximise the diversification of their investments in order to mitigate the consequences of the financial crisis.
Amid the international outbreak of COVID-19 and the resulting public uncertainty, we see that crime in general, including fraud, blackmail, money laundering and other economic crime, tends to grow. It basically makes sense to expect such activities from persons that have been involved in illegal activities and tried to exploit the weakest links of the existing legal framework and public order in their own interests. A similar illegal strategy is implemented in the present situation, in which people are focusing on other crucial and urgent issues and becoming less cautious or making rash decisions because of the emergency situation. Practice also suggests that the rising crime rates are directly linked to the circumstances caused by COVID-19.
Due to the emergency situation declared in Latvia for COVID-19 containment, companies as well as central and local government agencies have taken measures to protect their workers, customers and other persons against potential threats to their health in order to continue working to the extent possible in the emergency situation. Under the circumstances, a new type of information about individuals is additionally being gathered and processed, for example, whether they have any symptoms, whether the person has been in contact with anyone who might be infected, including any COVID-19 tests and their results, as well as other information relating to places someone has visited.
The government is working hard to put support measures in place for entities affected by the COVID-19 crisis. Last week the Cabinet of Ministers put into effect a number of rules concerning industries affected by the COVID-19 crisis and how employers in those industries qualify for idle-time benefit. Despite the original intention to restrict tax deadline extensions and idle-time benefit to entities operating in the listed industries, at the meeting of 26 March, the Cabinet of Ministers approved a set of criteria to make an affected entity in any industry eligible for idle-time benefit and tax holidays for up to three years. This article explores what we see as key points.
Many countries have seen a rapid drop in economic activity due to COVID-19 and are trying to adopt some extraordinary tax policy measures in order to limit the damage and protect business. A fast response is crucial when it comes to mitigating the impact of the crisis. This article explores some of the tax policy measures recently adopted in Europe and Latvia.
Governments and health supervisory agencies around the world have launched an all-out fight against COVID-19, but more needs to be done. Several countries have quarantined millions of people, and if the situation deteriorates, more countries might follow suit. COVID-19 has become a serious risk for the Latvian economy as well as globally.
