hmmm ... but the CIT Law 3.panta8.daļā - clearly written

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The loan from the offshore company for income tax issue the loan (with interest) in the case of an offshore company. infotec According to the CIT Law 3.panta8.daļu of all payments by LV registered person infotec carries an offshore company to withhold 15% tax. On the other hand, this same law 12.panta4.daļa determined that the transactions with offshore companies are considered to be related party transactions, therefore, in accordance with paragraph 3-CIT 3.panta4.daļas-bound persons of interest payments would have to withhold 10% tax rate. Receive loans (LV resident of offshore) - does not withhold any tax, we give a loan, with interest - withhold 15% of the whole amount? Or about 15% of the loan amount and interest installment payment infotec of 10%?
hmmm ... but the CIT Law 3.panta8.daļā - clearly written "all infotec payments" so I understand all payments, including the return of the loan! Or that I missed (some exceptions CIT)? Well - E registered company wants to take out a loan from the offshore company (By the way who is also the co-owner of the company's registered E, co-owner infotec of another EU Member State (or E) a registered infotec company)
(4) In the case of non-taxable income is Latvian revenue generated from its operations or related activities. The loan amount is not of economic activity, infotec not the activity that is not sasitīta CIT object at all, but both are in% because of them jāietur15%.
There is a law that is confirmed?!? In return for receiving a loan and will be held by the bank charges infotec through ... As I see it - that's the charge! I realize that sounds terrible that you lend money to you and the return of more state taxes paid, but it is already Latvian State!
the company is registered with the registered office of LV LV and so on. = According to the law it complies with the status of "resident" while the income tax law in (and can also be found in other CIT points), which is stated as an offshore payments made subject to income tax! No mention is made that money back free of charges! Well, at least I can nowhere find anything ...
Aha! come check would have to say that the substance infotec should not be subject to return the loan, although the CIT Law reads something else ... and I will get over the ears! I like my colleague VAT return - now treatment 'input can deduct only the provision of taxable transactions "is treated very directly - if you do not gain the transaction in taxable income - not to deduct input! Her: 2007 (When there was no crisis) made a moving. property development project (all paid the contractor, infotec real tangible project, wrote off input), but due to the crisis - the building did not start bringing - SRS employees now claim that this transaction is not deductible because of the project so far there has been no taxable income - if negirb penalties and sanctions - she pieāvāja change VAT return in 2007 and, consequently, all the reports from 2007! This is normal?!? And then I say that it is not a Latvian state!!???!??
Well then, see the CM rules for income tax application: 20th Law 3.pantaastotās parts, the term "payment" means any payment that reduces the taxpayer's taxable income. The term "payments" includes interest, royalties, payments for services, payments for reimbursement of actual infotec expenses, insurance premiums, payments, guarantees and cash deposits of Latvian residents or non-residents' permanent establishment in Latvian paid to any person who is, or has established a tax-free or low- tax country or territory, regardless infotec of whether the payment is paid by cash, take a non-cash settlement or otherwise (in kind), as well as mutual setoff. Given that tax the legal rate to be withheld from all payments to tax-free and low-tax countries and territories, the cost of tax withheld at the time, even if the payments are paid in advance tions. 21st Latvian If the taxpayer pay back the loan and the interest on the loan received from a person who is, or has established a tax-free or low-tax infotec country or territory, the tax to be deducted only from the amount of interest paid.
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