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Transfer pricing documentation requirements tracker

Based on the amendments to the law “On taxes and duties” in relation to the legal requirements for transfer pricing documentation, Deloitte has prepared a Transfer Pricing Documentation Requirements tracker.

The new transfer pricing requirements are synchronized with activities carried out by the Organization for Economic Co-operation and Development (OECD), and the updated transfer pricing guidelines for taxpayers and tax administrations. The requirements are applicable to related party transactions carried out in the financial year starting on or after 1 January 2018. Furthermore, in the context of the corporate income tax (CIT) reform, related party transactions are becoming increasingly important, and receive additional scrutiny from the tax authority.

Transfer Pricing Interactive Tool

Please indicate the parties you have transactions with in the respective financial year:

Option 1. Foreign related entity (shareholding starting from 20%)¹ or offshore² or related individual¹
Option 2. Local related entity (>50% shareholding)¹
No related party transactions

Please verify your selected options. No related party transactions cannot be selected simultaneously with another option.

Please specify consolidated transaction amount with parties as indicated Option 2 in the respective financial year:

Does not exceed 0.25 mEUR
Exceeds 0.25 mEUR

Please verify that you have selected one of the two options.

Dear client,

Thank you for using our tool!

According to the information provided by you we draw your attention that transactions between the entities must be arm's length in order to mitigate recharacterisation as deemed dividend distribution. Therefore, although, you are not required to prepare full transfer pricing documentation you must justify prices applied between the entities by preparing:

Functional analysis
Selection of the most appropriate transfer pricing method
Comparability analysis and analysis of comparable data.³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

Have you happen to have any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Dear client,

Thank you for using our tool!

According to the information provided by you we draw your attention to the following:

Transactions between the entities must be arm's length in order to mitigate recharacterisation as deemed dividend distribution. Therefore, although, you are not required to prepare full transfer pricing documentation you must justify prices applied between the entities by preparing:
- Functional analysis
- Selection of the most appropriate transfer pricing method
- Comparability analysis and analysis of comparable data.

Additionally, if two Latvian related entities having transaction(s) with each other are further involved in a transaction with related foreign or offshore entity, partial or full Local file to be provided within 90 days upon request by tax authority (with an opportunity of submission extension for 30 days).³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Barbara Žuromska.

Have you happen to have any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Please specify the turnover of the company for the respective financial year:

Does not exceed 50 mEUR
Exceeds 50 mEUR

Please specify consolidated transaction amount with parties indicated in Option 1 in the respective financial year:

Does not exceed 0.25 mEUR
Exceeds 0.25 mEUR, but does not exceed 5 mEUR
Exceeds 5 mEUR, but does not exceed 15 mEUR
Exceeds 15 mEUR

Please verify that you have selected an answer for both questions.

Dear client,

Thank you for using our tool!

According to the information provided by you we draw your attention that the Master file and Local file has to be submitted within 12 months after end of financial year.³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

Have you happen to have any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Dear client,

Thank you for using our tool!

According to the information provided by you we draw your attention that the Local file has to be submitted and Master file has to be prepared within 12 months after end of financial year. The Master file has to be provided within one month upon request.³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

Have you happen to have any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Dear client,

Thank you for using our tool!

According to the information provided we draw your attention that the Local file has to be prepared within 12 months after end of financial year. The Local file has to be provided within one month upon request.³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

Have you happen to have any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Dear client,

Thank you for using our tool!

According to the information provided by you, transfer pricing requirements are not applicable in this case.³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

In case of any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Please specify the turnover of the company for the respective financial year:

Does not exceed 50 mEUR
Exceeds 50 mEUR

Please specify consolidated transaction amount with parties indicated in Option 1 in the respective financial year:

Does not exceed 0.25 mEUR
Exceeds 0.25 mEUR, but does not exceed 5 mEUR
Exceeds 5 mEUR, but does not exceed 15 mEUR
Exceeds 15 mEUR

Please specify consolidated transaction amount with parties as indicated Option 2 in the respective financial year:

Does not exceed 0.25 mEUR
Exceeds 0.25 mEUR

Please verify that you have selected an option for all questions.

Dear client,

Thank you for using our tool!

According to the information provided by you we draw your attention that the Master file and Local file has to be submitted within 12 months after end of financial year.³

Dear client,

Thank you for using our tool!

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

In case of any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Dear client,

Thank you for using our tool!

Functional analysis
Selection of the most appropriate transfer pricing method
Comparability analysis and analysis of comparable data.³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

In case of any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Dear client,

Thank you for using our tool!

Functional analysis
Selection of the most appropriate transfer pricing method
Comparability analysis and analysis of comparable data.

Additionally, if two Latvian related entities having transaction(s) with each other are further involved in a transaction with related foreign or offshore entity, partial or full Local file to be provided within 90 days upon request by tax authority (with an opportunity of submission extension for 30 days).³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

In case of any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

In case of any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

Dear client,

Thank you for using our tool!

According to the information provided transfer pricing requirements are not applicable to you.³

For more detailed information on transfer pricing requirements in Latvia feel free to contact Barbara Žuromska.

In case of any additional questions with regard to VAT, CIT or any other matters, feel free to contact us.

Sincerely yours,
Deloitte Latvia

¹ For more details please see Article 1 para. 18 of Latvian Law on Taxes and Duties.

² For more details please see Cabinet of Ministers regulations No 655 “Regulations on low tax or no-tax jurisdictions and territories”

³ Please note that the information is designed to provide helpful highlights with regards to applicable transfer pricing requirements in Latvia. However, be aware that this information is of a general nature and cannot substitute the advice of a professional of any nature.

Get in touch

Barbara Žuromska

Director | Transfer Pricing

bzuromska@deloittece.com

+371 29375326

Barbara is an experienced director who specializes in transfer pricing and international tax matters for about 10 years. Barbara holds Bachelor's degree in Economics and LLM in Law and Finance that pr... More

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Transfer pricing documentation requirements tracker

Get in touch

Barbara Žuromska

Director | Transfer Pricing

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