Corporate - Significant developments

Last reviewed - 09 February 2024

Tax reform

Corporate income tax (CIT)

Latvia is regarded as offering a relatively favourable income tax regime, as due to the CIT reform, the approach to calculating CIT changed fundamentally in 2018. Under the current model, taxation of corporate profits is postponed until those profits are distributed as dividends or deemed to be distributed. Distributed profits are subject to 20% CIT (20/80 on the net amount of the profit distribution), resulting in application of an effective 25% rate.

From 2024, credit institutions and consumer crediting service providers are required to pay a tax surcharge of 20% in the taxation year (regardless of the profit distribution).

Availability of existing tax relief/tax attributes

Large investment relief (LIR) and reliefs for special economic zone (SEZ) and free port companies may still be claimed by reducing CIT on declared dividends.

Profits accumulated before 2018 can be utilised by declaring dividends free of CIT indefinitely.

Exit tax and hybrid mismatches

To complete the adoption of the Anti-Tax Avoidance Directive 2016/1164 (ATAD), a set of rules related to exit tax and hybrid mismatches were added to the CIT Act effective as of 12 February 2020. The CIT Act was supplemented with new rules on the tax treatment of assets a taxpayer moves abroad free of charge. There also has been adopted a new section of the CIT Act laying down the tax treatment of transactions that create hybrid mismatches. 

DAC6 Directive

Latvia has implemented Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (DAC6). The Taxes and Duties Act was amended, giving rise to the Cabinet of Ministers’ regulation concerning the Automatic Exchange of Information on Reportable Cross-Border Arrangements.

DAC6 applies to cross-border tax arrangements that are entered into by a European Union (EU) taxpayer with other entities in the European Union or non-EU countries. Such arrangements have to be reported to national tax authorities if certain criteria (hallmarks) are met.

The Latvian legislation is effective from 1 July 2020, and reports will retroactively cover arrangements implemented between 25 June 2018 and 1 July 2020.

DAC7 Directive

Latvia has implemented Council Directive (EU) 2021/514 (DAC7) on administrative cooperation in the field of taxation to extend the EU tax transparency rules and reporting obligations to digital platforms and platform operators. Digital platforms and platform operators are required to provide information on the income of sellers using digital platforms from 2023. These rules impose a reporting obligation on digital platforms operating within and outside the European Union.

The Latvian legislation is effective from 1 January 2023. Digital platforms and platform operators will have to file their first reports to the member states for 2023 by 31 January 2024.

Carbon Border Adjustment Mechanism (CBAM)

Latvia has implemented Council Directive (EU) 2023/956 on establishing a carbon border adjustment mechanism. CBAM rules apply only to EU-registered companies importing specified goods (e.g. aluminium, iron and steel, cement, hydrogen, fertiliser, and electricity) from third countries. The list of goods covered by CBAM will be gradually expanded, so importers are advised to monitor the CBAM rules.

Companies subject to CBAM are liable to file their first CBAM reports in January 2024. Up to January 2026, companies subject to CBAM will only have the reporting obligation, i.e. duty to file quarterly CBAM reports with the competent authority. As of 1 January 2025, the companies subject to CBAM should obtain authorised declarant status. An importer that fails to obtain such status may be fined or its imports prohibited. As of 1 January 2026, CBAM takes full effect and annual CBAM declarations and certificates become mandatory.