Transfer pricing

In the case of the transactions with the Russian Federation, transfer price documentation must be prepared

Article 15.2 of the Law "On Taxes and Fees" stipulates, among other things, that the taxpayer referred to in the Law on Corporate Income Tax - a resident or permanent establishment of a non-resident - substantiates the compliance of the transaction price with the market price in the transfer pricing documentation (global and local documentation or only local documentation) in transactions it carries out with other commercial companies or persons, if they are located or established in low-tax or tax-free countries or territories.

On July 1, 2023, new regulations of the Cabinet of Ministers on low-tax or tax-free countries and territories (regulation No. 333) came into force. At the same time, the list of these countries and territories was supplemented. The full list can be found here: /lv/current-list-of-low-tax-or-no-tax-countries-and-territories

The list of these countries now also includes the Russian Federation. Therefore, for transactions made after July 1, 2023 with any business partner registered in its territory, transfer pricing documentation must be prepared in accordance with the procedures specified in the Law "On Taxes and Duties". 

For more details on the criteria for documentation preparation and submission to the State Revenue Service, please see the information here or read our last article “Transfer pricing documentation - Is it ready for submission to State Revenue Service?

To discuss cooperation models we provide for the preparation of transfer pricing documentation, please get in touch with the Orients Audit & Finance Tax project manager and the author of this article, Ina Spridzāne, at

You can also find more tax-related news here:, or information on the Binding ruling of the State Revenue Service here:

Ina Spridzane

Tax project manager, Certified tax consultant