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SRS and interest rates in related party loans: what the Senate said about using the “average”

When the SRS addresses related party loans, the central issue is almost always the interest rate. In practice, a seemingly simple approach is often used: to compare the loan interest rate with the average indicators published by the Bank of Latvia and, if it exceeds the “average”, to make tax adjustments. The Senate of the […]

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Heat Procurement Price Cap Introduced: Amendments to the Energy Law and the New Thermal Energy Procurement Procedure from October 1, 2026

As of October 1, 2026, the procedure by which a thermal energy producer sells its produced thermal energy to a district heating system operator will change. These changes are included in the amendments to the Energy Law, which the Saeima supported on February 12 with a clearly defined objective: to address price fluctuations in the

Heat Procurement Price Cap Introduced: Amendments to the Energy Law and the New Thermal Energy Procurement Procedure from October 1, 2026 Lasīt vairāk »

Henceforth, the UR shall not verify the rights arising from categories of shares or stocks

When receiving a company’s documents for registration, the Register of Enterprises (UR) primarily verifies whether they formally comply with the requirements of regulatory enactments. Private agreements between shareholders (e.g., specific provisions on the sale of shares) are generally not evaluated by the UR; however, an assessment of the compliance of the provisions included in the

Henceforth, the UR shall not verify the rights arising from categories of shares or stocks Lasīt vairāk »

Report on Controlled Transactions | Transfer Pricing in Practice: How the Approach Determines the Outcome

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

Report on Controlled Transactions | Transfer Pricing in Practice: How the Approach Determines the Outcome Lasīt vairāk »

Controlled Transactions Overview | How the SRS Performs Transfer Pricing Adjustments in Practice and How CIT Surcharges Arise

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

Controlled Transactions Overview | How the SRS Performs Transfer Pricing Adjustments in Practice and How CIT Surcharges Arise Lasīt vairāk »

Controlled Transactions Report | How the SRS Selects Companies for Transfer Pricing Audits in Practice

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)

Controlled Transactions Report | How the SRS Selects Companies for Transfer Pricing Audits in Practice Lasīt vairāk »

Controlled Transactions Report | Structured Data Available to the SRS and its Impact on Transfer Pricing Risks

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

Controlled Transactions Report | Structured Data Available to the SRS and its Impact on Transfer Pricing Risks Lasīt vairāk »

Controlled Transactions Report | Why the arm’s length principle also applies to transactions between Latvian companies

There is a persistent belief among entrepreneurs that transfer pricing regulations primarily apply to international transactions, while transactions between Latvian companies are perceived as low-risk from the outset. Although there is some basis for this view, in practice it often leads to an incomplete understanding of the arm’s length principle and erroneous conclusions regarding the

Controlled Transactions Report | Why the arm’s length principle also applies to transactions between Latvian companies Lasīt vairāk »