Vita Liberte
Managing Partner
vita.liberte@bdo.lv
Restructuring legal entity and thin capitalisation optimisation - BDO Law assisted the client and prepared all the necessary documents for investment in-kind made by the Client and when increasing Client’s share capital.
Tax consultations included comprehensive tax analysis of corporate income tax, values added tax, and real estate Land Register’s fees. Tax Department prepared 4 Company restructuring scenarios which were an alternative solution for liquidation process. As well, Firm’s Tax Department prepared and implemented a corporate income tax thin capitalization solution for financial years 2020 and 2021.
Subsequently, the Client implemented one of the suggested scenarios and saved EUR 440 000 in comparison to its original liquidation plan.
Janis Zelmenis
Managing Partner
janis.zelemenis@bdo.lv
Tax matters of SE relocations and destination research - BDO Law converted the bank from AS (Joint Stock Company) to SE (Societas Europaea).
Tax Department provided an opinion on tax aspects related to the transfer of the head office of a SE from Latvia to another country. As well, provided services regarding the comparison of tax environment in three possible destination jurisdiction - Germany, Estonia, and Lithuania. Provided an opinion on tax aspects related to the transfer of the head office of a SE from Latvia to another country.
The tax scope of this comparison included specifics of tax residence related matters, corporate income tax, including taxation of dividend distribution and relevant tax treaties, value added tax in accordance with Council Directive 2006/112/EC, salary taxes. As well as memorandum on comprehensive tax risk assessment of head office exit from Latvia was included.
Vita Liberte
Managing Partner
vita.liberte@bdo.lv
Tax Structuring project - BDO Tax Department prepared consultations regarding the development of tax efficient structure for Client to expand its business to U.S.
The Project was divided into three phases. First phase was provided to the Client during 2020, this phase included:
- Feasibility evaluation of the proposed project and designing an appropriate company structure for the group’s U.S. operations.
- Preparing a high-level review for the operations of the Latvian corporation in the U.S. to determine the risk of a permanent establishment created by the Latvian personnel, as well as potential structures to minimize U.S. tax and administrative burden.
Janis Zelmenis
Managing Partner
janis.zelemenis@bdo.lv
Preparation of full-scope Transfer Pricing documentation - BDO prepared full scope transfer pricing documentation, including master file and local file, for a broad range of intra-group transactions for the purpose of tax-efficient business operations for submission to State Revenue Service.
Transfer pricing documentation involved analysis of compliance with the arm’s length principle for group companies in Latvia, Europe, and Russia. This documentation covered transactions such as:
- Production and resale (medical products)
- Financial transactions.
- Low value-added transactions and others.
This matter covered documentation of complex supply chain transactions, since client is an international company, with subsidiaries worldwide.
