We have written about the burning question of how to calculate the value of a related-party loan for the current year. This is crucial in determining whether the taxpayer is required to prepare and submit transfer pricing (TP) documentation to the State Revenue Service (SRS) within 12 months after the end of the financial year. As the deadline for 2018 is almost upon us (31 December 2019), PwC approached the Ministry of Finance and the SRS for comment. This article explores the opinion shared by the two bodies and PwC’s understanding of their comment.
In October 2019, the State Revenue Service (SRS) published an advance tax ruling on the corporate income tax (CIT) and personal income tax (PIT) treatment of dividends paid out of profits formed by proceeds from selling a subsidiary. The ruling answers some long-awaited questions about the tax implications.
As the calendar year 2019 is nearing its end, some taxpayers are facing a deadline for filing their transfer pricing (TP) documentation. This article explores the deadline and some technical challenges that are likely to prevent taxpayers from meeting it.
Under Latvian transfer pricing (TP) rules, a taxpayer reaching a statutory threshold for controlled transactions must prepare and file TP documentation with the State Revenue Service (SRS) within 12 months after the end of the financial year. The SRS has recently issued a crucial interpretation stating that the acquisition and disposal of assets includes acquiring shares in another company and is therefore considered a transaction for TP purposes.
As the calendar year 2019 is nearing its end, some taxpayers are facing a deadline for filing their transfer pricing (TP) documentation. This article explores the deadline and some technical challenges that are likely to prevent taxpayers from meeting it.