Transfer pricing

28.02.2020

Future of digital tax: OECD Pillar Two (3/9/20)

Tax CIT Transfer pricing

Wrapping up our previous article “Unified approach to addressing tax challenges in digital economy,” this article explores the OECD’s proposals for international taxation rules within Pillar Two.

21.02.2020

Future of digital tax: OECD’s Pillar One (2/8/20)

Tax Transfer pricing

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.

14.02.2020

Unified approach to addressing tax challenges in digital economy (2/7/20)

Tax Transfer pricing

Following up on the topic of digitalisation discussed in our Flash News article “Taxing permanent establishments in digital economy” on 23 August 2018, we have prepared a series of articles summarising the key points of Pillar One and Pillar Two, documents recently issued by the OECD.

13.12.2019

New tax opinion on amount of related party loan for current year (1/50/19)

Tax Transfer pricing

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.

10.12.2019

New tax opinion on amount of related party loan for current year 1/50/19

Free access Tax Transfer pricing

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.

29.11.2019

Submission of transfer pricing documentation (2/48/19)

Tax Transfer pricing

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.

26.11.2019

Transfer pricing documentation for share purchase and sale: SRS comment 1/47/19

Free access Tax Transfer pricing

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.

26.11.2019

Submission of transfer pricing documentation 1/48/19

Free access Tax Transfer pricing

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.

22.11.2019

Transfer pricing documentation for share purchase and sale: SRS comment (2/47/19)

Tax Car tax Transfer pricing

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.

02.11.2019

Cash pool: transfer pricing aspects (3) (1/44/19)

Tax Transfer pricing

To complete our series of articles on the transfer pricing (TP) aspects of a cash pool, this article explores what data and sources are used in practice for setting fees (interest rates) for cash pool members depositing and borrowing cash.

25.10.2019

Cash pool: transfer pricing aspects (2) (2/43/19)

Tax Transfer pricing

To pick up where we left off about the transfer pricing aspects of a cash pool, this article explores ways of setting fees for cash pool members, including the treasurer, according to the OECD Base Erosion and Profit Shifting (BEPS) discussion draft on financial transactions published in July 2018 (“BEPS report”).

25.10.2019

Proposed penalty for failure to file country by country report (1/43/19)

Stamp Tax Transfer pricing

On 1 October 2019 the Cabinet of Ministers debated and supported proposals for amending the Taxes and Duties Act to impose a new penalty for failure to duly file a country-by-country report.

22.10.2019

Proposed penalty for failure to file country by country report 1/43/19

Free access Tax Transfer pricing

On 1 October 2019 the Cabinet of Ministers debated and supported proposals for amending the Taxes and Duties Act to impose a new penalty for failure to duly file a country-by-country report.

23.08.2019

Cash pool: transfer pricing aspects (1) (1/34/19)

Tax Transfer pricing

Multinational enterprises tend to set up cash pools to optimise disposable intragroup funds and minimise their reliance on external financing. But setting up a cash pool creates the need to prove the arm’s length nature of cash pool transactions and, possibly, to prepare transfer pricing (TP) documentation. This series of articles will be exploring key TP considerations regarding cash pool transactions between related parties in the light of Latvian TP rules and best practices recommended by the OECD BEPS project.

11.07.2019

Fellow subsidiaries as related parties in transfer pricing (2/28/19)

Tax CIT Transfer pricing

Some of the substantial changes made to Latvia’s transfer pricing (TP) rules effective from 1 January 2018 prescribe how corporate income tax (CIT) payers should identify related parties before reporting and analysing their mutual transactions in their TP documentation. This article explores whether fellow subsidiaries are treated as related parties and offers a practical example of identifying this status.

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