Introduction
On 1 January 2026, amendments to Article 15.² of the “Law on Taxes and Duties” entered into force, introducing several significant changes to Latvia’s transfer pricing regulation. The aim of these amendments is to expand documentation requirements, introduce a more structured reporting system, refine applicable thresholds, and strengthen the tax administration’s oversight tools.
New Requirement – Controlled Transactions Report
The most significant innovation is the introduction of the Controlled Transactions Report as a new component of transfer pricing documentation.
Under the amendments, taxpayers will be required to submit this report if the total value of controlled transactions exceeds EUR 250,000 in the relevant reporting year (Section 15.², Paragraph 9.¹ of the Law). The report must include structured information on the type of transaction, direction, amount, counterparty, as well as the transfer pricing method applied and the comparable data used.
Going forward, transfer pricing documentation will consist of three main parts:
- Global Documentation (Master File);
- Local Documentation (Local File);
- Controlled Transactions Report.
The amendments also clarify the thresholds that determine which documentation must be submitted:
| Type of Documentation | Condition | Deadline |
| Global Documentation (Master File) | Transaction value > EUR 20 million, or turnover > EUR 50 million and transaction value > EUR 5 million | Must be prepared within 12 months after the end of the reporting year and submitted within one month upon request from the State Revenue Service (SRS) |
| Local Documentation (Local File) | Transaction value > EUR 250,000 | Must be prepared within 12 months after the end of the reporting year and submitted within one month upon request from the SRS |
| Controlled Transactions Report | Transaction value > EUR 250,000 | Must be submitted to the SRS within 12 months after the end of the reporting year |
What Will the Impact Be?
Naturally, the administrative burden for all taxpayers will increase. However, in my view, for taxpayers who already monitor transfer pricing and perform at least basic analyses, completing the Controlled Transactions Report should not pose significant difficulties. For example, a company that prepares and submits Local Documentation to the tax authority each year will already be able to explain which method was chosen, what comparables were used, and other relevant details–and therefore will be able to present this information in a structured format.
The structured approach introduced by the amendments is intended as an addition to traditional transfer pricing documentation, not a replacement. This is reasonable, as every business and every transaction is unique and cannot be fully captured within a single template. At the same time, structured information helps standardise the presentation of results and facilitates administrative oversight.
The greatest increase in compliance burden will likely fall on companies with controlled transaction values between EUR 250,000 and EUR 5 million. Previously, these companies were required to prepare transfer pricing documentation within 12 months after the end of the reporting year, but only had to submit it upon request–within one month. Now, this group must submit the structured report, which means performing at least a minimum level of analysis in accordance with the required format.
Relief for Smaller-Scale Transactions
The amendments provide that transactions with a total value not exceeding EUR 90,000 during the reporting year may be considered non-material and therefore are not required to be included in transfer pricing documentation.
The previous threshold was EUR 20,000, which theoretically means a reduction in administrative burden for small and medium-sized enterprises. However, in practice, taxpayers have so far evaluated the tax risk in relation to the cost of managing that risk. With a EUR 20,000 threshold, the maximum potential tax exposure (if the entire transaction were rejected) is EUR 5,000. The penalty for non-submission–1%–amounts to EUR 200, meaning that many taxpayers opted for only a very general, “tick-the-box” analysis.
Therefore, increasing the threshold should be viewed positively. It should be noted, however, that this change does not exempt taxpayers from the obligation to comply with transfer pricing principles even for transactions below EUR 90,000.
Can These Amendments Be Seen as an Improvement to the Transfer Pricing Documentation Environment?
This question can be assessed from two perspectives – that of the State Revenue Service (SRS) and that of taxpayers.
From the SRS perspective, the changes are undoubtedly positive, as structured information provides an additional layer of data on potential transfer pricing risks. Contrary to some opinions suggesting that the information will merely duplicate what “the SRS already sees,” transfer pricing risks cannot always be identified from annual reports, VAT returns, or corporate income tax declarations.
Structured data will enable more efficient transaction analysis through automated tools and will expand the SRS’s ability to perform risk assessment and respond proactively, even before initiating a tax audit.
From the perspective of businesses, the amendments introduce additional administrative workload, since even smaller companies (for example, those with EUR 250,000 in controlled transactions) will be required to prepare documentation and submit the report.
In practice, however, some companies may choose to prepare only the minimum required structured report, leaving full transfer pricing documentation to be completed if specifically requested by the SRS.
Summary
Overall, I view these amendments positively. They provide the SRS with additional control capabilities and access to timely information that can be processed quickly to identify potential transfer pricing risks–well before the initiation of a formal tax audit.
At the same time, the amendments encourage a broader range of businesses to address transfer pricing matters proactively, without waiting for a request from the SRS. Although the changes impose additional obligations, for companies that already submitted documentation annually, the burden will not increase significantly. For companies with controlled transactions below EUR 5 million, the requirement to complete at least basic transfer pricing analysis will help reduce risks and lower the likelihood of unexpected tax control measures by the SRS.