Page 36 - Central and Eastern European Transfer Pricing Review

36 | CEE Transfer Pricing Review

Do tax authorities have requirements Other recent Is there a fling fee for APAs?
or preferences regarding databases developments It is planned that the fee per APA would
for comparables? be LVL8,000.
No. The tax authority itself uses the As of 1 January 2013 there is a transfer
Amadeus database. However, there are pricing documentation requirement Does the tax authority publish APA
no requirements or recommendations in Latvia. The amendments to the data either in the form of an annual
on the use of any specifc database. law also introduce APAs. Cabinet of report or through the disclosure of
Some entities prefer to use the Amadeus Ministers Regulations that will provide data in public forums?
database because it is more likely that the practical guidance on concluding APAs No.
tax authority would obtain the same, or at are still in development.
least similar, benchmarking study results. Please provide some information
on how successful the APA program
Tax treaty/double tax
What level of interaction do tax is and whether there are any known
authorities have with customs resolution diffculties?
authorities? What is the extent of the double tax APAs are a new option that have not
High. It is combined. treaty network? yet been implemented. It is planned
Extensive. that conclusion of an APA would take
Are management fees deductible?
6 months.
Yes. If extensive, is the competent
authority effective in obtaining
Are management fees subject to double tax relief? Language
withholding? In which language or languages
Almost always.
Yes. can documentation be fled?
When may a taxpayer submit an There are no language requirements.
Are year-end transfer pricing adjustment to competent authority? Therefore submission of transfer pricing
adjustments permitted?
No formal rule. documentation in English is acceptable.
Yes. The taxpayer may reduce its However, the tax authority is entitled
corporate income tax base by the May a taxpayer go to competent to ask for a translation of either the full
difference between intra-group prices authority before paying tax? documentation or parts in Latvian.
and market prices by which its qualifed Yes.
related party has increased its corporate It is uncommon to submit transfer pricing
income tax base. Advance pricing documentation in languages other than
Latvian or English.
Other unique attributes? arrangements
None. What APA options are available,
if any?
The following options are available:
advance rulings

APAs are possible.

KPMG in Latvia

Steve Austwick
Tel: +371 67 038 000
Email: saustwick@kpmg.com

As email addresses and phone numbers change
frequently, please email us at transferpricing@
kpmg.com if you are unable to contact us via the
information noted above.
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