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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

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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 »

Controlled Transaction Reports in Practice: 4 Errors the SRS Will Spot First

In recent years, transfer pricing regulation in Latvia has gradually shifted away from formal document checks toward evaluating the economic substance of transactions. Recent amendments to Section 15.² of the Law on Taxes and Duties clearly reinforce this direction: the State Revenue Service (SRS) will receive structured information regarding transactions with related parties, which the

Controlled Transaction Reports in Practice: 4 Errors the SRS Will Spot First Lasīt vairāk »

What are transfer prices and which companies do they apply to?

Companies often believe that transfer pricing does not apply to them, as it is only applicable to large multinational corporations. However, in reality, transfer pricing affects significantly more companies than it might initially seem. Transfer prices are the prices at which related companies trade with each other. Transfer pricing regulation exists at the level of

What are transfer prices and which companies do they apply to? Lasīt vairāk »

Why must the price comply with the arm’s length principle?

Transfer pricing has long affected not only international groups but also local companies. They have become a daily reality for Latvian businesses, especially in cases where a company cooperates with related parties: subsidiaries, board members, ultimate beneficial owners, relatives of officials, or foreign partners belonging to the same group. The arm’s length principle is one

Why must the price comply with the arm’s length principle? Lasīt vairāk »

Report on Controlled Transactions – a New Burden, Not an Improvement in Transfer Pricing

The draft law, which intends to supplement Section 15.2 of the Law “On Taxes and Duties” with a new Paragraph 9¹, is currently being considered in the second reading by the Saeima. Given the current pace of progress and the support of the responsible Budget and Finance (Tax) Committee, the adoption of these changes is

Report on Controlled Transactions – a New Burden, Not an Improvement in Transfer Pricing Lasīt vairāk »