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.
Picking up where we left off in last week’s article “Unified approach to addressing tax challenges in digital economy,” this article explores recent proposals for international taxation rules within Pillar One of the OECD’s Work Programme.
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.
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.