In transfer pricing matters, businesses are often convinced that the risk is theoretical or applies only to ‘very large’ or international companies. Practice shows otherwise. Often, the decisive factor is not the transaction volume or structural complexity, but how well the company is prepared to justify its prices when the SRS (State Revenue Service) asks […]
When the State Revenue Service (SRS) initiates a transfer pricing audit, entrepreneurs often expect a discussion regarding the documentation format or specific methodological nuances. However, in practice, the SRS focus is usually much more pragmatic – on whether the company’s financial results correspond to what an independent market participant would achieve under similar circumstances. If
Among entrepreneurs, the question “Why did the SRS come specifically to us?” is still frequently heard. This is often followed by the assumption that the audit is random or related to some formal error. In practice, this view is increasingly less aligned with reality. In the field of transfer pricing, the State Revenue Service (SRS)
In recent years, transfer pricing regulations in Latvia have undergone a quiet but significant transformation. While previously the tax administration often focused on the formal existence or absence of documentation, now the focus is increasingly shifting towards the economic substance of transactions and the figures that characterize them. With the new amendments to Section 15.²
