Nowadays more and more multinational enterprises decide to enter into an agreement with tax authorities for setting the price of a transaction between related parties in advance (Advance Pricing Agreement or APA). This article explores the Latvian practice of entering into an APA.
The OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (the “Convention”) was approved on 24 November 2016. As many as 69 countries (including Latvia and Lithuania) signed it on 7 June 2017, with eight countries (including Estonia) having expressed their intention to sign it. Under the Convention, Latvia has opted to apply only provisions for implementing the minimum standard of the action plan on BEPS and to ensure as far as possible that the new provisions complement the existing provisions of the covered tax treaties, or that new provisions not amending the provisions of the covered tax treaties are applied.