No Match Found
Our professional experience suggests that paragraph 3.3.2 of the Cabinet of Ministers’ Rule No. 802, “Transfer Pricing Documentation and Procedures for Entering Into an Advance Pricing Agreement Between the Taxpayer and the Tax Authority for a Transaction or a Type of Transactions”, which states that the taxpayer’s transfer pricing (TP) documentation should include financial information and tables showing how the financial data used in applying the TP method is linked to the financial statements, has taxpayers confused as a maze of legal interpretation.
We have written about the burning question of how to calculate the value of a related-party loan for the current year. This is crucial in determining whether the taxpayer is required to prepare and submit transfer pricing (TP) documentation to the State Revenue Service (SRS) within 12 months after the end of the financial year. As the deadline for 2018 is almost upon us (31 December 2019), PwC approached the Ministry of Finance and the SRS for comment. This article explores the opinion shared by the two bodies and PwC’s understanding of their comment.
Under Latvian transfer pricing (TP) rules, a taxpayer reaching a statutory threshold for controlled transactions must prepare and file TP documentation with the State Revenue Service (SRS) within 12 months after the end of the financial year. The SRS has recently issued a crucial interpretation stating that the acquisition and disposal of assets includes acquiring shares in another company and is therefore considered a transaction for TP purposes.
Sazinieties ar mūsu transfertcenu komandu, PwC Latvia