Page 32 - CEE Tax Guide 2024
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Latvia                                                                                                                 administration (e.g. submitting application forms, issuing   Personal income tax / Social security system
                                                                                                                                  certificates, granting permissions, etc.) are also subject
                                                                                                                                  to stamp duty.                                      A progressive PIT rate was introduced starting from
                                                                                                                                                                                      January 1, 2018. From January 1, 2022, it includes the
                                                                                                                                   VAT options in                                     following: 20% is applied for income of less than EUR
                                                                                                                                   Latvia                 Applicable / limits         20,004 per year; 23% for income between EUR 20,004
                               SIA Mazars Latvia                                                                                                                                      and EUR 78,100 per year; and 31% for income exceeding
                               Duntes str 6-213,                                                                                                         From July 1, 2021 the OSS system   EUR 78,100 per year. A maximum amount for the object
                               Riga, Latvia, LV-1013                                                                               Distance selling     is in force. A VAT registration threshold   of social contribution tax is set for 2022, 2023 and 2024
                               Phone: +371 67379031                                                                                                     of EUR 10,000 per year is applicable.  in the amount of EUR 78,100.
                               www.mazars.lv                                                                                       Call-off stock                  ü                  The tax on annual income of more than EUR 78,100 per
                                                                                                                                   VAT group registration          ü                  year is calculated in a recapitulative order when submitting
                                                                                                                                                                                      the annual income declaration. If a payroll tax book is not
                                                                                                                                   Cash accounting – yearly   EUR 300,000/year applicable to private
                                                                                                                                   amount in EUR (approx.)  entrepreneurs or agricultural companies.  submitted at a place of employment, the salary tax rate
                                                                                                                                                                                      is 23% regardless of monthly income.
                                                                                                                                   Import VAT deferment            ü
           Corporate taxes and other direct taxes              Tax exempt capital gains: from 2018 onwards, distributed                                 Timber and related services, dealings   Also, from July 1, 2022, the non-taxable minimum has
                                                               profit from the sale of directly owned shares (except for                                 involving scrap metal, construction   been increased from 350 EUR to 500 EUR (please see
           Since 2018, CIT is, in general, payable only on the   shares of low/tax free companies) is not subject to CIT                                services, grain crops, precious metals,   wage calculations below).
           distribution of profit: dividends (also interim dividends),   unless the company has held the relevant shares for fewer   Local reverse charge  game console supplies, supplies   Income from capital and capital gains is taxed with
           payments qualifying as dividends, non-business expenses,   than 36 months, or the shares belong to a company the                            of ferrous and non-ferrous semi-finished   a 20% PIT rate.
           loans issued to related parties, interest payments subject   majority of whose assets by value is comprised of real                                 metal products.
           to thin capitalization rules, bad debts to be written   estate located in Latvia. Exemption does not apply              Option for taxation                                Active incomes fall under the scope of the SSC system:
           off, transfer pricing adjustments, liquidation quota,   where the main purpose of setting up the taxpayer or the            letting of real estate      No                 individual social contributions equal a total of 34.09%,
           etc. The CIT rate is 20% of the gross taxable value   structure is to benefit from the holding regime (i.e. tax                                                            of which the employer’s contribution is 23.59% and the
           (expense/distribution value) or 25% of the net value (i.e.   optimization or avoidance of taxes has taken place).       supply of used real estate      ü                  employee’s contribution is 10.5%. Benefits in kind earned
           a 20/80 rate).                                                                                                          VAT registration          EUR 50,000/year          within employment are taxed with PIT and SSC at standard
                                                               Tax exemption is not applicable to profits from the sale            threshold                                          rates. The examples below show the cost to the employer
           Since 2018, the following thin capitalization rules are   of financial instruments (e.g. investment fund notes,                                                            and employee in the cases of the minimum and the
           applicable: (1) the debt/equity ratio exceeds 4 to 1; (2)   securities, bonds, etc.) or to royalties and interest received.                                                average wage in the private sector.
           the amount of interest paid exceeds EUR 3 million as well
           as 30% of EBITDA. If either of the two thin capitalization   A withholding tax (WHT) of 20% is applied to management
           thresholds are exceeded, the interest payment will   and consulting service fees paid by Latvian companies
           be subject to 25% CIT from the net excess interest value.  to foreign companies; 3% WHT is applied to remuneration      Wage related taxes in Latvia                        Minimum wage                Average wage
                                                               paid to a foreign company for the disposal of real                                                                                                 in private sector
                                                               estate located in Latvia, or for the disposal of shares                                                                                            in EUR
            Transfer pricing in Latvia                         holding real estate located in Latvia; 5% WHT is applied                                                                in EUR
                                                               to remuneration paid to a foreign company for renting                                                                     700                        1,549
            Arm’s length principle  ü      Since 2005          or leasing of real estate in Latvia; and 20% WHT is applied
            Documentation liability  ü     Since 2013          to all payments to offshore companies. WHT may                      Total wage cost                                        865      123.59%          1,914      123.59%
                                                               be avoided under the active international treaty network                                  Vocational training contribution   –        0.00%             -        0.00%
            APA                  ü         Since 2013          consisting of more than 63 double tax treaties.                                                  Social contribution tax   165      23.59%            365      23.59%
            Country-by-                     Since 2017
            Country liability    ü                             VAT and other indirect taxes                                        Gross salary                                           700      100.00%          1,549      100.00%
            Master file-local file                                                                                                                               Personal income tax*   25,30      20.00%            277      20.00%
            (OECD BEPS 13)                 Since 2018          The general VAT rate is 21% for the sale of goods and                                          Employees' contributions   73,50     10.50%            163      10.50%
            applicable                                         services. A reduced rate of 12% is used, for example, for
            Penalty                                            medical goods, periodicals, accommodation services,                 Net salary*                                            601      85.89%           1,109      71.60%
                                        Penalty of up to 1% of the   and thermal energy supplied to private individuals.          *  When calculating the applicable PIT, it is assumed that the employee has submitted its salary tax book to the employer. It is also
              lack of documentation  ü  controlled transaction, but not   Furthermore, a reduced 5% VAT rate is applicable for the   assumed that the non-taxable minimum applied is EUR 0 in case of average wage (calculated for each taxpayer individually) and in
                                        exceeding EUR 100,000.  supply of fruit and vegetables typically grown in Latvia.          case of minimum wage – EUR 700.
                                        20% tax on gross value   As of January 1, 2022, the VAT rate for books, news
                         tax shortage  ü  of underpayment
                                        + late payment interest  websites, etc. has been reduced from 12% to 5%, and
                                                               on e-books from 21% to 5%. A 0% rate is applicable for the
                                      Generally, related parties are   export of goods and for the supply of Covid-19 vaccines
                                       two or more natural or legal
                                       persons, or representatives   and devices and services related to Covid-19 treatments.
                                       of such persons or groups
            Related parties     > 50%  under specified conditions   Exemptions are in place for postal services, medical
                                                               and health services, certain financial services, etc.
                                       listed by law (e.g. parent and
                                        subsidiary; shareholding;   Entrepreneurs with annual sales of less than EUR 50,000
                                        majority of votes; etc.).  are exempt from VAT obligations. Monthly returns are                          Oļegs Sējāns
                                                               electronically recorded. The options/limits based on the
                                       Low value-added services:                                                                                 Managing Partner
            Safe harbors        No         5% mark-up.         EU Directive are determined in the VAT Act.                                       Phone: +371 67379031
            Level of attention paid by Tax                     Other indirect tax types in Latvia include excise and                             E-mail: olegs.sejans@mazars.lv
            Authority                        8/10              customs duties, and some transactions related to public

           32    Mazars                                                      Central and Eastern European tax guide 2024          Central and Eastern European tax guide 2024                                             Mazars   33
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