Different classes of shares in a SIA and the related tax considerations
2 July 2026
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Transfer Pricing
Transfer pricing has become one of the central areas of tax risk in modern business. Both in Latvia and globally, tax authorities are paying increasing attention to how prices are set and transactions structured between related parties.
Our experts provide a full spectrum of transfer pricing services - from advisory, policy development and documentation preparation to client representation in disputes with tax authorities and international transfer pricing procedures. We help businesses structure transactions to be tax-safe and aligned with their business strategy.
Controlled Transactions Report
From 2026, companies with related-party transactions above EUR 250,000 per year must file a new structured report with the SRS. Try our 1:1 copy of the EDS form and let REMPE confirm it is filled in correctly.
Why Is Transfer Pricing Important?
Tax Risk Mitigation
Incorrect transfer pricing may result in tax adjustments, penalties and late payment interest.
Supply Chain and Profit Structure Optimisation
A transfer pricing policy enables you to structure the supply chain and profit allocation in line with functions, risks and economic reality, while optimising tax efficiency at group level.
Regulatory Compliance
Companies with related-party transactions are required to comply with transfer pricing regulations and, in certain cases, to prepare the requisite documentation.
Transfer Pricing Services Offered by REMPE
Industry and Transaction Specifics
We understand that transfer pricing issues can be particularly complex in certain industries and transaction types. REMPE experts have accumulated experience advising on various transactions across different sectors, including:
Manufacturing and Logistics
supply chain structures, warehousing and distribution centres.
Wholesale and Retail
goods procurement and sales structures between related parties.
Services
professional, consulting and support services.
Financial Transactions
loans, guarantees, cash-pooling structures and various financing solutions (peer-to-peer, etc.).
IT and Digital Companies
development, valuation and licensing of intellectual property and other intangible assets.
Support Functions
provision of centralised management, marketing, IT, accounting and other shared services.
Who Requires Transfer Pricing Documentation?
Transfer pricing documentation is a mandatory requirement for companies that conduct transactions with related parties.
Who must prepare transfer pricing documentation and when?
- Companies whose transactions with related parties exceed the thresholds set out in applicable regulations.
- A Local File must be prepared where the value of controlled transactions in a financial year exceeds EUR 250,000.
- A Master File must be prepared where the value of controlled transactions in a financial year exceeds EUR 20 million.
- Documentation must be updated regularly to reflect the company's current operations and transactions.
What do the transfer pricing documentation requirements include?
- The company must be able to substantiate that related-party transactions comply with the arm's length principle.
- The documentation must include information on the company, its transactions, functions, risks, methods applied and financial analysis.
- Documentation must be submitted to the State Revenue Service (SRS) within 30 days of a request.
- In the case of inadequate or non-compliant documentation, the SRS may make transfer pricing adjustments and impose penalties.
In Latvia, transfer pricing is one of the priority areas for the State Revenue Service (SRS), and requirements are becoming increasingly stringent - making timely documentation preparation critically important.
