A practical guide to transfer pricing

We encourage taxpayers to use a guide put together by PwC that offers handy tips for documenting and reporting related-party transactions for CIT purposes. The below instructions for reporting and documenting transfer prices are designed mainly to help your staff responsible for the technical side of interpreting TP issues. These instructions do not provide a final interpretation in assessing your related-party transactions or TP issues.

Step 1 checks whether the taxpayer has any related parties.

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Step 2 indicates an obligation to check whether related parties have made any transactions or entered into commercial or financial relationships. If so, the total value of related-party transactions should be reported on the CIT return.

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Step 3 finds out whether the CIT base will include any deemed distributions arising from related-party transactions (TP adjustment). If an adjustment is required, the difference between the amounts of related-party transactions should be reported on the CIT return.

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Step 4 checks whether the taxpayer is required to prepare and file TP documentation to prove that the prices are arm’s length.

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We offer a functional support tool “Transfer Pricing  Requirement Calculator” where the taxpayer can answer a set of questions (e.g. assessing whether the company has any related-party transactions and what amounts are involved) to work out the total value of related-party transactions to be reported on the CIT return and understand whether the taxpayer is required to prepare any particular form of TP documentation and file it with the SRS.

Access "Transfer Pricing Requirement Calculator" here

Contact us

Tatjana Koncevaja

Tatjana Koncevaja

Head of Transfer Pricing Practice, PwC Latvia

Zane Smutova

Zane Smutova

Senior Manager in Transfer Pricing, PwC Latvia

Tel: +371 67094400

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