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LatviaValsts ieņēmumu dienests

VID explains the one-year timetable for advance pricing agreements

The period runs from the start of the APA procedure. If agreement has not been reached, continuation depends on whether further negotiations remain worthwhile.

By Taxxa AI OyPublished 28 August 2026

Tax

Latvian taxpayers seeking an advance pricing agreement should track the date on which VID starts the agreement procedure. VID's service guidance describes a one-year period from that point, with continuation by mutual agreement where the parties consider further work worthwhile. The underlying regulation links termination after a year to both failure to agree and the lack of a useful basis for continuing.Likumi

That timetable concerns negotiating the agreement. Under the regulation, VID first examines the application and supporting information and decides whether to start the procedure. If it starts, VID informs the taxpayer of the commencement date and the responsible official. The procedure can then involve further requests for information or explanations about the proposed terms.

The application identifies the taxpayer and related counterparty, the transaction or type of transaction, and the proposed method for establishing an arm's-length price. It includes the legal justification for the method and application, the period the agreement should cover and any earlier reporting years concerned. The agreement's duration cannot exceed five years from its conclusion.VID

The fee is €7,114. The regulation requires 20% before the application is submitted and 80% after notification of VID's decision to start the agreement procedure. Until the relevant portion is received, VID does not examine the application or continue the procedure, respectively. Taxpayers should distinguish that payment trigger from the eventual signing of an agreement.

A concluded agreement sets out the covered facts, transactions and reporting years, the pricing method and relevant assumptions, together with monitoring and other conditions. If the taxpayer follows the agreement and its business has not changed inconsistently with it, the law restricts the tax administration from adjusting the agreed arm's-length price in an audit.VID Keeping the agreed facts and assumptions aligned with the business is therefore part of using the agreement.

The legal basis is Section 16.1 of the law “Par nodokļiem un nodevām” and Cabinet Regulation No. 802, particularly paragraphs 5–11 and 16–20.

Track the notified procedure start date and the fee payment triggered by that decision.

Sources