Contents:

• The reform that destroyed Ancient Rome

• We are more equal!

• Magna Carta

• Fight or pay

• Capital tax

• But how to determine the value of property?

• The emergence of income tax

• What is profit and is it permissible to earn it?

• Presumptive tax

• Salary tax

Read more

Read more

Contents:

• What happened?

• Questions to the EU Court of Justice

• Is the case admissible before the ECJ?

• ECJ: both criteria must be assessed

• Not only that

• What does Latvian law say?

• Latvian courts rarely apply provisional measures

  • Are tax disputes in Latvia only for the wealthy?

  • Are Latvian courts essentially violating EU law?

Read more

Contents:

• Right to privacy

• How?

• Perhaps the SRS could have refrained from providing this information to the landlord?

• From the outset, the taxpayer himself must be asked

  • In the private sector

  • In public administration - differently

• The proportionality of obtaining such information must also be assessed

• Other procedural issues

  • The tax administration must also comply with a number of other restrictions on obtaining information

  • The same is not permitted in administrative proceedings as in criminal proceedings

  • The builders’ cartel case

• If you are interested in this topic...

Read more

Contents:

• What is a fisc?

• What kind of tax was there in Ancient Rome?

• Don’t tax you, don’t tax me, tax that guy behind the tree...

• Should a non-dom tax be introduced?

• But why did the UK reject it?

• Doesn’t it sound similar to what is happening in Ukraine now?

Read more

Of course, this is subjective for everyone. My latest discovery in this regard is a concert in Vilnius recommended by my brother—French singer Zaz. Here is a link to her latest album, and below are some photos from her concert, which was absolutely fantastic.

Read more

Contents:

• What did the ECJ say?

• Latvian law is contrary to the VAT Directive

• What are the consequences?

Read more

Contents:

• Philip Baker (+video)

  • The creation of the UN Tax Convention

  • What are some examples of taxpayer rights?

  • Sources where taxpayer rights can be found

    • National

    • EU

    • International

    • Tax obligations arising from the pact

  • Summary of taxpayer rights

Philip Baker (+video presentation)

Read more

• Typical situation

• What might the Latvian State Revenue Service be interested in in such situations?

  • Capital growth

  • Permanent establishment

  • CFC

• What is Latvian Maxima disputing in the EU court?

  • Why did we, unlike other consultants, not recommend such a structure?

• Neo Group Lithuanian case in the EU court

• But many people do it!

  • Parallel income

  • Investment before sale

A typical situation

So, a Latvian tax resident (natural person) owns 100% of the shares in a Cypriot company, which in turn owns a portion of the shares in a Latvian company. This situation is not uncommon, as 20 years ago it was a consultant’s bread and butter - to persuade businesspeople that this was safer, more correct, etc. Let’s model what the consequences are now and what some of the latest EU court cases are in this regard.

What might the Latvian State Revenue Service be interested in in such situations?

Read more

Contents:

• What happened?

• What did the SRS claim?

• What are the consequences?

• I would like to highlight this particular claim by the SRS

  • Fraud?

  • Unjustified fiscal advantages?

  • Example with 0%

  • Example with 21%

  • The essence of neutrality

• Unjustified state enrichment

• What the Senate is asking the ECJ and what my answers would be

• Applicable VAT law

• Reflections on the case

  • It is irrelevant when ownership rights are transferred

  • Incoterms do not determine the moment of transfer of ownership rights

  • It is irrelevant that these were excise goods

  • How to determine whether it is a triangle or a quadrangle?

  • Why is it not advantageous for Latvia not to register VAT payers retroactively?

  • What are LLP partners? Offshore companies?

What happened?

This case concerns the application of VAT to supplies of excise goods (petroleum products) under the deferred tax regime. The deliveries involved sellers in Latvia, intermediaries in Estonia and the United Kingdom, as well as buyers in other EU countries. The goods were delivered from Latvia to end buyers in other EU countries. Transport was provided by buyers in third EU countries. For now, it looks like a classic triangle.

Read more

Contents:

• What happened?

• Where is the problem?

  • GAAR

  • Rates

• Where do aggressive planning ideas come from?

Read more

Blog content:

1. What was the dispute about?

2. Residence is a variable, not a constant

3. No registration of non-residents

4. Must be explained, even if the SRS does not agree from the outset

5. Top 3 practical recommendations

What was the dispute about?

A person applied to the SRS with a request to recognize their non-resident status. The SRS refused, and this person challenged it in court. The Senate ultimately ruled that the SRS’s decision on whether or not a person is a Latvian tax resident is not an administrative act and therefore cannot be challenged. What does this mean?

Read more

In this blog:

1. What happened?

2. What did the Senate say?

3. What should you watch out for in such situations?

4. Practical consequences

5. Recommendations

What happened?

In October 2025, the Senate reviewed a case in which a member (shareholder) of a company contested a tax invoice issued to the company by the State Revenue Service (SRS). However, the shareholder did not contest it immediately after the invoice was issued, but only after the SRS requested that the shareholder personally pay the invoice. This was because the shareholder was included in the list of persons of risk. The company itself did not contest the invoice.

What did the Senate say?

Read more

Blog content:

1. The essence of the matter

2. How can I know if I am obliged to respond?

3. What does this mean in practical terms?

4. Examples 1-4

5. Recommendations

6. Is ‘Consult first’ a hidden tax inspection or even an audit?

   1. What is a tax inspection?

   2. What is a SRS audit?

   3. Is ‘consult first’ a formal process?

7. If you want to read more about this

As always, for more complex matters, Sorainen’s 30+ Baltic tax team + WTS international network + IBFD database with tax regulations in every country in the world will be happy to assist you. Write to us (janis.taukacs@sorainen.com) or call us (29 139 300).

The essence of the case

In this case, the SRS requested information from the company about its employees, asking for details about the objects where the employees had performed and continue to perform work, as well as about transactions with customers to whom these employees had provided services. The Senate pointed out in this case that a distinction must be made between whether I, as the recipient of the SRS letter, have the right to contest this request immediately or only if it later results in a decision by the SRS.

If there is an obligation to respond (rather than a right to be heard), the SRS request is contestable. If there is no obligation to respond, the request is not an administrative act and cannot be contested. If the SRS request cannot be contested, it will usually be contestable later if the SRS’s actions result in a decision that is unfavorable to a person. Then, in the process of challenging this decision, you will also be able to complain about everything that happened before the decision was made.

However, the issue turned out to be more complex than I had initially thought.

Read more

The closest warmth to Europe in January

In my previous blog, I wrote that Egypt was one of the first countries. So, it had every opportunity to develop the most. The sun closest to Europe in January is the perfect reason for scantily clad people speaking all European languages to walk on the beach here. Why don’t Europeans flock here?

How much does an apartment cost?

The guide proudly announced that Latvians also tend to buy apartments here in Hurghada. How much do they cost? On average, around EUR 1,000 per square meter, or around EUR 100,000 for a large two-room apartment. Not so cheap after all.

EUR 200 a month is a good salary

I chat with a local guy who works at the hotel by the pool. Every day, without holidays. He earns around EUR 200 per month and is happy because he has a job. Others outside the hotel do harder work for even less pay. I asked him why. He immediately threw a stone into the government’s garden in a hushed voice. At the same time, he looked around carefully to make sure no one could hear him. Even the best hotels in Egypt do not seem to stand out particularly, for example, compared to the hotels on offer in Antalya.

Read more

1. CBAM. From January 1, 2026, import duties must be paid on CO2 emissions generated outside the EU from the production of the following goods: cement, electricity, fertilizers, iron and metal, aluminum, hydrogen. Each of these goods has its own CN (customs) code, which is specified in the relevant regulation. Until now, these only had to be declared at th…

Read more

In this blog:

• 🦣 Cave people share mammoth meat with hearth keepers and cave painters.

• 🛡️ Villagers behind fortifications negotiate with raiders offering “protection.”

• 🌊 Ancient Egyptians measure the water level of the Nile to calculate possible taxes.

• 📜 Strict tax collectors collect duties.

• 🏗️ Pyramid construction with forced labor, symbolizing the blurred line between taxes and work.

Read more

From 2024.

I already wrote about CBAM in 2024, when the relevant EU regulation came into force. The main categories of goods affected are: cement, electricity, fertilizers, iron and metal, aluminum, hydrogen. Annex 1 of the regulation contains a precise list of goods based on their CN codes. Until now, importers had to submit reports on imports of listed goods into the EU using a special CBAM portal. Restrictions and payments do not apply to countries originating in EFTA.

From 2026

Imports - only with authorized CBAM declarants

From 1.1.26, the goods mentioned above may only be imported into the EU by authorized CBAM declarants - the companies themselves or their (indirect customs) representatives. Before importing these goods, the person must submit an application via the CBAM register, providing detailed information about the applicant. The competent authority in the country where the applicant is registered will then grant the status of authorized CBAM declarant if the criteria are met. In Latvia, this application can be submitted to the EDS, and the SRS will review it within 120 days (80 days for A-rated companies). Here is SRS information about these declarants, and here is information about the declarant portal. The 50t volume restrictions do not apply to imports of electricity and hydrogen.

Payments

Importers must also purchase emission allowances (CBAM certificates). The number of CBAM certificates purchased must be equal to the number of greenhouse gas emissions.

Member States will sell certificates through a central platform set up by the EC. The price of CBAM certificates is calculated weekly based on the average auction price of European emission allowances. Here is a portal where you can calculate these import costs yourself.

Member States will be able to buy back surplus certificates, but the number of certificates bought back cannot exceed 1/3 of the total number of CBAM certificates purchased by the authorized CBAM declarant in the previous calendar year. The OIM payment is also expected to be reduced for carbon taxes paid outside the EU.

Continued:

• Example of CBAM cost calculation

• Penalties are also envisaged

• Practical impact

Read more

Sorainen has also published a summary of tax news for 2026, which came into force on January 1, 2026. What seems to be the most important in the December Tax News?

Legislation

Amendments to Cabinet Regulation No. 899 “Procedures for the Application of the Provisions of the Law on Personal Income Tax“ clarify the following issues:

• regarding compensation amo…

Read more

Contents: legal regulation (when property is joint property of spouses and when it is separate property) in Estonia, Lithuania, and Latvia. Taxes. Conclusions.

In Estonia

If registered in the land register – only one of the spouses

In our northern neighbors, property acquired during cohabitation belongs to both spouses or partners by default. However, this is not always reflected in the relevant registers, where often only one of the spouses is listed as the owner. This could cause certain practical problems.

For example

..if someone wants to purchase real estate registered to one of the spouses, they should check not only the land register, but also the publicly available register of spouses in Estonia to make sure that the spouses have not chosen a different regime, such as separation of property.

In a 2017 case...

...the Estonian Supreme Court ruled that even the notary had made a mistake by not checking that the property belonged to both spouses. In addition, the court also found that the entry in the real estate register stating that the property belonged to only one of the spouses was incorrect. Thus, in essence, the court placed the family’s property relations above the property rights reflected in the land register.

What are the consequences of this?

The buyer essentially risks having the transaction contested if they have purchased real estate from one spouse without the consent of the other spouse, because they have not checked the property register of the spouses and partners. This was decided by the Estonian Supreme Court a year later, allowing the deceived spouse to recover the sold property in joint ownership.

The same applies to capital shares

Furthermore, this regulation applies not only to real estate, but to any property. In 2022, a woman in Estonia managed to regain ownership rights to shares in two Estonian companies. Her husband had previously disposed of these shares by investing them in a Maltese fund, thereby preparing his pension fund. The woman succeeded despite the fact that only her husband was listed as the owner of the shares in the Estonian Securities Register (depository) and later on the NASDAQ stock exchange.

What if the spouses are divorced?

Read more