Business Operations in the Baltic States (Portfolio 7025)

Tax Management Portfolio, Business Operations in the Baltic States, No. 7025, is intended to provide U.S. and other foreign businesses interested in conducting operations in the Baltic countries with an overview of the laws governing business activity in each of Estonia, Latvia and Lithuania with an emphasis on the tax perspective. To view this Portfolio, visit Bloomberg Tax for a free trial.

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Description

Tax Management Portfolio, Business Operations in the Baltic States, No. 7025, is intended to provide U.S. and other foreign businesses interested in conducting operations in the Baltic countries with an overview of the laws governing business activity in each of Estonia, Latvia and Lithuania with an emphasis on the tax perspective.

The Portfolio chapters begin with a key facts overview, a general introduction to each of the Baltic countries and those aspects of the respective legal environments relevant to investment and trade issues. This is followed by a review of the various business forms available and the main business regulatory considerations. There is a detailed review of the legal framework for taxation in each of the Baltic countries as it applies to individuals and legal entities, both residents and nonresidents. Direct and indirect taxes are addressed.

The Worksheets include sample articles of association, lists of double taxation agreements and residence certificate forms needed to avail of treaty benefits.

This Portfolio may be cited as Papp, Rozenblat, Kikkamägi, Jansons, Akermane, and Balcius, 7025 T.M., Business Operations in the Baltic States.

Authors

Sven Papp

Sven Papp is one of the leading and most experienced Corporate and M&A Lawyers in Estonia. He has unique and broad international experience both as an Attorney and as a General Counsel having worked at White & Case in New York and in its Stockholm offices, the Swedish-French consulting company SIAR-Bossard in Stockholm and in Swedish Match East Europe in Stockholm. Sven has an unrivalled track record having over the past 20 years acted as Lead Legal Adviser for a large number of landmark local and international M&A transactions across the Baltic and Nordic region.

Dmitri Rozenblat

Dmitri Rozenblat is a Senior Associate at Ellex Raidla. He specializes mainly in tax law with specific expertise in international taxation, tax planning, VAT and customs taxation, expatriate taxation and related areas. He also represents clients in tax disputes. Dmitri also has extensive experience in mergers and acquisitions, restructurings and corporate law. In combination with the tax law expertise, this enables him to successfully advise clients in M&A deals and in day-to-day corporate matters.

Mirko Kikkamägi

Mirko Kikkamägi is an Associate at Ellex Raidla specializing mainly in mergers and acquisitions. His outstanding knowledge of corporate finance has proven instrumental in complex corporate cross-border transactions. Before joining Ellex Raidla in 2017, Mirko worked in Clifford Chance Frankfurt office's English law banking team, specializing in financing transactions in Central and Eastern Europe and Turkey.

Zinta Jansons

Zinta Jansons, J.D. Seton Hall, School of Law, 1998, admitted to practice in New York and New Jersey, Certified Latvian Tax Advisor. Zinta is a partner at Ellex Klavins and head of the tax practice. She has more than 17 years’ experience consulting on legal and tax issues in the Baltics. Zinta has led the firm's work on numerous transaction projects in the finance sector as well as complex M&A transactions and related structuring matters. She regularly advises foreign investors on entering the Latvian market. Zinta lectures at the Riga Graduate School of Law.

Zane Akermane

Zane Akermane, LL.M., University of Latvia, assistant sworn attorney, tax lawyer at Ellex Klavins. Zane has extensive experience in advising companies and individuals regarding complex tax issues in relation to cross-border transactions. Her main focus is VAT and corporate income tax. Zane has advised many multinationals and leading regional businesses concerning tax compliance and cross-border tax issues, as well tax planning matters with a focus on regulated industries. Zane regularly publlishes articles on current court practice related to tax issues in Latvia.

Gintaras Balcius

Gintaras Balcius, Master in Economics, 1990, Tax Advisor at Ellex Valiunas. Gintaras has more than 25 years’ experience advising companies and individuals on the proper balance between tax risk and tax savings. Gintaras’ areas of expertise are tax optimization, tax compliance, international taxation, tax disputes, and complex reorganizations for tax optimization purposes. His deep technical knowledge of tax laws combined with practical, commercial and industry experience enables him to provide effective support across a range of tax litigation procedures. His professional strengths include an ability to understand the business operations and business needs of the client as well as proven skills that allow him to communicate effectively both with international and local companies and with the Lithuanian tax authorities.

Table of Contents

Detailed Analysis
CHAPTER 10: ESTONIA
10:I. Estonia — The Country, Its People and Economy
A. The Country
B. The People
C. The Economy
1. General
2. Transportation and Communication
3. Political Organization
4. Foreign Relations
10:II. Operating a Business in Estonia
A. Foreign Investment Regulation
1. Opportunities
2. Incentives
3. Restrictions
a. Entities
b. Real Estate
c. Profit and Cash
B. Currency and Exchange Controls
1. Currency
2. Exchange Controls
C. Trade and Commerce Regulation
1. Imports and Exports
a. Licenses and Quotas
b. Customs Duties and Other Taxes
c. Documentation
2. General Regulation of Business
a. Anticompetitive Practices (Monopolies and Cartels)
b. Mergers
c. Restrictive Trade Practices
d. Price Controls
e. Securities Regulation
3. Licensing and Franchising in Estonia
a. Patents
b. Trademarks and Trade Names
c. Industrial Know-How
d. Copyrights
D. Immigration Regulations
1. European Citizens
2. Non-European Citizens
a. Registration of Temporary Employment
b. Temporary Residence Permit for Employment
E. Labor Relations
1. General Aspects
2. Employment Contracts
3. Working Conditions
F. Financing the Business
10:III. Forms of Doing Business in Estonia
A. Principal Business Entities
1. Sole Proprietorship
2. Limited Liability Company
3. Partnership
4. Branch of a Foreign Corporation
5. Other Entities
B. Private Limited Company (Osaühing)
1. Incorporation
a. Field of Activity
b. Business Name
c. Shareholders
d. Share Capital
e. Incorporation Procedure and Foundation Documents
f. Costs of Incorporation
2. Operation
a. License
b. Amendment of the Articles of Association
c. Increases and Reductions of Share Capital
d. Acquisition of Own Shares
e. Corporate Officers
f. Shareholders' Meetings
g. Meetings of the Management Board and the Supervisory Board
h. Books and Records
i. Financial Statements
j. Distributions of Profits
k. Reserves
3. Statutory Merger
4. Dissolution and Liquidation
5. Reorganization
C. Public Limited Companies
1. Formation
a. Formation Procedure
b. Share Capital
2. Operation
a. Increases and Reductions of Share Capital
b. Acquisition of Own Shares
c. Corporate Officers
d. Shareholders' Meetings
e. Meetings of the Management Board and the Supervisory Board
f. Books and Records
g. Financial Statements
h. Distributions of Profits
i. Reserves
j. Liquidation
D. Partnership
1. General Partnership
a. Formation
b. Administration
c. Dissolution
2. Limited Partnership
a. Formation
b. Administration
c. Dissolution
E. Branch of a Foreign Corporation
1. Registration
2. Liability
3. Books and Records
F. Other Corporate Entities
1. Commercial Association (Tulundusühistu)
2. European Company (Societas Europea)
3. European Cooperative Society (Societas Cooperativa Europea)
4. Contract of Partnership
10:IV. Principal Taxes
A. Sources of Authority in Tax
1. Legislative
a. Organization of Tax Law
b. Other Legislative Documents that Can be Used to Interpret the Law
c. Legislative Process
d. Constitutional Challenge
2. Administrative Guidelines
3. Court System
B. Income Tax (Tulumaks)
1. Corporate Income Tax
2. Personal Income Tax
C. Social Tax (Sotsiaalmaks)
D. Land Tax (Maamaks)
E. Gambling Tax (Hasartmängumaks)
F. Value Added Tax (Käibemaks)
G. Customs Duty (Tollimaks)
H. Excise Duties (Aktsiis)
I. Heavy Goods Vehicle Tax
J. Local Taxes
10:V. Taxation of Domestic Companies
A. What Is a Domestic Company?
B. Corporate Income Tax
1. Taxation of Income
a. Dividends and Other Profit Distributions
b. Fringe Benefits
c. Gifts, Donations and Costs of Entertaining
d. Non-Business Expenses
e. Payments Not Related to Business
f. Advance Payments of Credit Institutions
g. Loans as Hidden Profit Distributions
h. Other Distributions
i. Exemptions
2. Accounting
a. General
b. Financial Year and Taxation Period
c. Accounting Methods
d. Reserves
e. Valuation and Inventories
3. Calculation of Profit
4. Share Options
a. General Overview
b. Taxation
c. Tax Exemption
d. Tax Treatment of Alternative Option Schemes
5. Deductions
6. Loss Carryforwards and Carrybacks
7. Tax Credits
8. Tax Rates and Calculation of Taxable Income
9. Assessment and Filing
10. Audit Process, Statute of Limitations and Interest for Late Payment
a. Tax Audits
b. Statute of Limitations
c. Interest
d. Collection of Taxes
e. Penalties
f. Appeal
g. Refund
h. Binding Preliminary Ruling
11. Consolidated Returns
12. Reorganizations
a. Change of Legal Form
b. Mergers, Spin-offs, etc.
c. Cross-Border Transactions
d. Liquidation
e. Other Payments Made from Equity
C. Other Taxes
1. VAT
2. Transfer Tax
3. Real Estate Tax
4. Local Taxes
5. State and Notary Fees
10:VI. Taxation of Non-residents — Companies
A. Non-residents Companies Defined
B. Method of Taxation
1. Remuneration Paid to Nonresident Member of a Management or Controlling Body 
2. Business Income
3. Gains Derived from a Transfer of Property
4. Commercial Lease and Royalties
5. Dividends
6. Interest
C. Assessment and Filing
1. Domestic Law 
2. Income Tax Treaties 
10:VII. Taxation of a Branch
A. General
B. Determination of Taxable Income
C. Method of Taxation
D. Subsidiary v. Branch
10:VIII. Taxation of Partnerships
10:IX. Taxation of Other Business Enterprises: Sole Proprietors
10:X. Taxation of Individuals — Residents
A. Scope of Taxation
B. Residence
C. Taxable Income
D. Tax-Exempt Income
E. Deductions
1. Housing Loan Interest
2. Training Expenses
3. Gifts and Donations
F. Foreign Tax Credit
G. Rates and Calculation of Taxable Income
H. Assessment, Audit, Filing and Collection of Taxes
1. Income Tax Returns
2. Payment
3. Assessment Procedure
4. Appeals
I. Statute of Limitations for Assessment
10:XI. Taxation of Non-residents — Individuals
A. Who Are Non-residents?
B. Method of Taxation
1. Income Derived from Work or from the Provision of Services
2. Gains Derived from a Transfer of Property
3. Commercial Lease and Royalties
4. Dividends
5. Interest
6. Other Income
7. Remuneration Paid to Non-resident Artists and Sportspersons 
C. Assessment and Filing
1. Domestic Law 
2. Income Tax Treaties 
10:XII. Estate, Inheritance, Transfer and Gift Tax
A. Inheritance and Gift Tax
B. Transfer Tax
10:XIII. Inter-Company Pricing
A. Scope of the Provision
B. Determination of Arm's-Length Price
C. Documentation Requirements
D. Availability of Advance Pricing Agreements or Rulings on Pricing
E. Competent Authority
10:XIV. Special Provisions Relating to Tax Haven Operations
A. What Is a Tax Haven Operation?
B. Taxation of Income of Legal Persons Located in Low Tax Rate Territories
C. Controlled Foreign Corporations
10:XV. Avoidance of Double Taxation
A. General
1. Individuals
a. Exemption
b. Foreign Tax Credit
2. Companies
a. Exemption
b. Foreign Tax Credit
B. Tax Treaties
1. General
2. Taxation of Business Income
a. Permanent Establishment
b. Industrial or Commercial Profits (Business Profits)
3. Taxation of Investment Income
a. Dividends
b. Interest
C. Tax Treaties with the United States
1. Income Tax Treaty
a. Income and Capital Gains from Real Property
b. Business Profits
c. Royalties
d. Avoidance of Double Taxation
2. Estate/Inheritance and Gift Tax Treaty
3. Intergovernmental Agreement (IGA) Pursuant to FATCA
CHAPTER 20: LATVIA
20:I. Latvia — The Country, Its People and Economy
20:II. Operating a Business in Latvia
A. Foreign Investment Regulation
1. Opportunities
2. Incentives
a. Incentives for Companies Operating in Special Economic Zones
b. Investment Incentive
c. Research and Development Relief
3. Restrictions
B. Currency and Exchange Controls
C. Trade and Commerce Regulation
1. Imports and Exports
a. Licenses and Quotas
b. Custom Duties and Other Taxes
c. Documentation
2. General Regulation of Business
a. Monopolies
b. Mergers
c. Restrictive Trade Practices
d. Price Controls
e. Securities Regulation
3. Licensing and Franchising in Latvia
a. Patents
b. Trademarks and Trade Names
c. Industrial Know-How
d. Copyrights
D. Immigration Regulations
E. Labor Relations
F. Financing the Business
20:III. Forms of Doing Business in Latvia
A. Principal Business Entities
1. Sole Proprietorship
2. Limited Liability Companies and Joint Stock Corporations
3. Partnership
4. Branch of a Foreign Corporation
5. Other Entities
B. Limited Liability Companies and Joint Stock Corporations
1. Formation
a. Purpose Clause
b. Corporate Name
c. Incorporators
d. Articles of Incorporation
e. Capital Stock
f. Incorporation Procedure
g. Costs of Incorporation
2. Operation
a. License
b. Amendment of Articles
c. Increases and Reductions of Capital Stock
d. Acquisition of Own Stock
e. Corporate Officers
f. Shareholders' Meetings
g. Directors' Meetings
h. Books and Records
i. Financial Statements
j. Dividends and Other Distributions of Profits
k. Reserves
3. Dissolution
4. Liquidation
5. Reorganizations
C. Other Corporate Entities
D. Partnerships
1. Formation
2. Administration
3. Dissolution
E. Branches of Foreign Corporations
1. Registration
2. Liability
3. Books and Records
F. Other Business Entities
G. Classification of Foreign Entities
20:IV. Principal Taxes
A. Sources of Authority in Tax
1. Legislative
a. Organization of the Tax Law
b. Other Legislative Documents that Can Be Used to Interpret the Law
c. Legislative Process
d. Constitutional Challenge
2. Administrative
3. Courts
B. Income Tax
C. Estate/Inheritance and Gift Tax
D. Value Added Tax
E. Capital Investment Tax
F. Payroll Tax
G. Trade Tax
H. Net Worth Tax
I. Local Taxes
1. General
2. Real Estate Tax
3. Real Property Transfer Fee
4. Excise Duty
5. Customs Duty
6. Passenger Car and Motorcycle Registration Tax
7. Passenger Car Tax
J. Other
20:V. Taxation of Domestic Corporations
A. What Is a Domestic Corporation?
B. Corporate Income Tax
1. Taxation of Worldwide Income
2. Accounting
a. General
b. Accounting Periods
c. Accounting Methods
d. Inventories
e. Reserves
3. Calculation of Gross Income
a. General
b. Capital Gains
c. Dividend Income
d. Income from Foreign Sources
e. Stock Options
f. Other Inclusions in Gross Income (Increases in Taxable Income)
g. Exclusions from Gross Income (Reductions of Taxable Income)
4. Business Expenses
a. General
b. Organizational Expenses
c. Travel and Entertainment Expenses
d. Interest and Royalties
e. Taxes
f. Depreciation and Amortization
g. Obsolete Equipment
h. Charitable Contributions
i. Capital Losses
j. Casualty Losses
k. Reserve Accounts
l. Bad Debts
m. Inventory Write-downs
n. Rent (Lease Payments)
o. Salaries and Wages
p. Other Deductions from Gross Income
5. Capital Expenditure
6. Loss Carryovers and Carrybacks
7. Tax Credits
a. Foreign Tax Credit
b. Investment Tax Credit
c. Other Credits
8. Tax Rates and Calculation of Taxable Income
9. Assessment and Filing
10. Audit Process and Statute of Limitations for Assessment and Collection of Taxes
11. Consolidated Returns
12. Reorganizations
a. Change of Legal Form
b. Mergers, Spin-offs, etc.
c. Cross-border Transactions
d. Liquidation
13. Advance Rulings
C. Other Taxes
1. Dividend Tax
2. Capital Investment Tax
3. Value Added Tax
4. Trade Tax
5. Real Estate Tax
6. Local Taxes
20:VI. Taxation of Foreign Corporations
A. What Is a Foreign Corporation?
B. Determination of Taxable Income
C. Method of Taxation
D. Assessment and Filing
20:VII. Taxation of a Branch
A. Determination of Taxable Income
B. Method of Taxation
C. Subsidiary v. Branch
20:VIII. Taxation of Partnerships
20:IX. Taxation of Other Business Entities
A. Individual Undertaking
B. Societies
20:X. Taxation of Resident Individuals
A. Scope of Taxation
B. Residence
C. Determination of Gross Income
1. Employment Income
2. Business Income
3. Income from Investment and Capital Gains
a. Investment Income
b. Capital Gains
4. Income Arising as a Result of Loans and Reduced Interest Rates
D. Allowances, Deductions and Credits
E. Rates and Calculation of Taxable Income
1. Rates
a. In General
b. Microenterprise Tax
c. Solidarity Tax
2. Calculation of Taxable Income
F. Assessment and Filing
G. Audit Process and Statute of Limitations for the Assessment and Collection of Taxes
20:XI. Taxation of Nonresident Individuals
A. General
B. Business Income
C. Investment Income
D. Capital Gains
E. Method of Taxation
20:XII. Estate/Inheritance/Transfer and Gift Tax
A. Estate, Inheritance or Transfer on Death Tax
B. Gift Tax
20:XIII. Inter-Company Pricing
A. Scope of the Provision
B. Determination of Arm's-Length Price
C. Documentation Requirements
D. Availability of Advance Pricing Agreements or Rulings on Pricing
E. Competent Authority
20:XIV. Special Provisions Relating to Multinational Corporations
A. Foreign Family Foundations
B. Tax Haven Operations
C. Controlled Foreign Corporations
20:XV. Avoidance of Double Taxation
A. Foreign Tax Credits
B. Tax Treaties
1. Tax Treaty Negotiation and Ratification Process
2. Procedure for Claiming Reduced or No Withholding, or a Refund of Tax Withheld
3. Taxation of Business Income
a. Permanent Establishment
b. Industrial or Commercial Profits
c. Minimizing the Taxation of Business Income Under a Tax Treaty
4. Taxation of Investment Income
a. Investment Income Defined
b. Withholding Tax Rates
C. Tax Treaties with the United States
1. 1998 Latvia-United States Tax Treaty
2. Estate and Gift Tax Treaty
3. Intergovernmental Agreement Pursuant to FATCA
4. Other
CHAPTER 30: LITHUANIA
30:I. Lithuania — The Country, Its People and Economy
30:II. Operating a Business in Lithuania
A. Foreign Investment Regulation
1. Opportunities
2. Incentives
a. Incentives in Free Economic Zones
b. Investment Incentive
c. Research and Development Relief
d. Film Production Incentive
3. Restrictions
B. Currency and Exchange Controls
C. Trade and Commerce Regulation
1. Imports and Exports
a. Licenses and Quotas
b. Custom Duties and Other Taxes
c. Documentation
2. General Regulation of Business
a. Monopolies
b. Mergers
c. Restrictive Trade Practices
d. Price Controls
e. Securities Regulation
3. Licensing and Franchising in Lithuania
a. Patents
b. Trademarks and Trade Names
c. Industrial Know-How
d. Copyrights and Related Rights
D. Immigration Regulations
E. Labor Relations
F. Financing the Business
30:III. Forms of Doing Business in Lithuania
A. Principal Business Entities
1. Sole Proprietorship
2. Joint Stock Corporation
3. Partnership
4. Branch of a Foreign Corporation
5. Other Entities
B. Joint Stock Corporation
1. Formation
a. Purpose Clause
b. Corporate Name
c. Incorporators
d. Articles of Incorporation
e. Capital Stock
f. Incorporation Procedure
g. Costs of Incorporation
2. Operation
a. License
b. Amendment to Articles of Association
c. Increases and Reductions of Capital Stock
d. Acquisition of Own Stock
e. Corporate Officers
f. Shareholders' Meetings
g. Directors' Meetings
h. Books and Records
i. Financial Statements
j. Dividends and Other Distributions of Profits
k. Reserves
3. Statutory Merger
4. Dissolution
5. Liquidation
6. Reorganization
C. Other Corporate Entities
D. Partnership
1. Formation
2. Administration
3. Dissolution
E. Branch of a Foreign Corporation
1. Registration
2. Liability
3. Books and Records
F. Other Business Entities
G. Classification of Foreign Entities (i.e., Classification Method)
30:IV. Principal Taxes
A. Sources of Authority in Tax
1. Legislative
a. Organization of the Tax Law
(1) International Agreements for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (DTT)
(2) EU Legislation in Respect of Taxes and Customs Duties
(3) Domestic Tax Legislation
b. Other Legislative Documents that Can be Used to Interpret the Law
c. Legislative Process
d. Constitutional Challenge
2. Administrative
3. Courts
B. Corporate Income Tax
C. Value Added Tax
D. Excise Duties
E. Real Estate Tax
F. Land Tax
G. Tax on Environmental Pollution
H. Personal Income Tax
I. Social Security Contributions
J. Compulsory Health Insurance Contributions
K. Guarantee Fund Contributions
L. Long-Term Employment Fund Contributions
M. Other Taxes
30:V. Taxation of Domestic Corporations
A. What Is a Domestic Corporation?
B. Corporate Income Tax
1. Taxation of Worldwide Income
2. Accounting
a. General
b. Accounting Periods
c. Accounting Methods
d. Inventories
e. Reserves
3. Calculation of Gross Income
a. General
b. Capital Gains
c. Dividend Income
(1) Dividend Income Received from Lithuanian Entities
(2) Dividend Income Received from Foreign Entities
d. Income from Foreign Sources
e. Stock Options
f. Other Inclusions in Gross Income
g. Exclusions from Gross Income
4. Business Expenses
a. General
b. Organizational Expenses
c. Travel and Entertainment Expenses
d. Interest and Royalties
e. Taxes
f. Depreciation and Amortization
g. Equipment Retired from Service
h. Sponsorship and Charitable Contributions
i. Ordinary Losses
j. Capital Losses
k. Casualty Losses
l. Reserve Accounts
m. Bad Debts
n. Inventory Write-downs
o. Rent
p. Salaries and Wages
q. Other Deductions from Gross Income
5. Capital Expenditures
6. Loss Carryovers and Carrybacks
7. Tax Credits
a. Foreign Tax Credit
b. Investment Tax Credit
c. Other Credits
8. Tax Rates and Calculation of Taxable Income
9. Assessment and Filing
a. Annual CIT Return and/or Annual Fixed Rate CIT Return
b. Advance CIT Return
c. Return on Amounts Paid to a Foreign Entity
d. Return on CIT Calculated and Paid in Respect of Dividends
e. Other Reporting Requirements
10. Audit Process and Statute of Limitations for Assessment and Collection of Taxes
11. Consolidated Returns
12. Reorganizations
a. Change of Legal Form
b. Mergers, Spin-offs, etc.
c. Cross-Border Transactions
d. Liquidation
13. Advance Rulings
a. Binding Ruling
b. Advance Pricing Agreement
c. Non-binding Ruling
C. Other Taxes
1. Taxation of Dividends
a. Dividends Received from or Paid to Lithuanian Entities
b. Dividends Received from Foreign Entities
c. Dividends Paid to Foreign Entities
2. Capital Investment Tax
3. VAT
4. Trade Tax
5. Real Estate Tax
6. Local Taxes
7. Excise Duties
30:VI. Taxation of Foreign Corporations
A. What Is a Foreign Corporation?
B. Determination of Taxable Income
C. Method of Taxation
1. Investment Income and Passive Payments
2. Business Income
D. Assessment and Filing
30:VII. Taxation of a Branch
A. Determination of Taxable Income
B. Method of Taxation
C. Subsidiary v. Branch
30:VIII. Taxation of Partnerships
30:IX. Taxation of Other Business Entities
30:X. Taxation of Individuals — Residents
A. Scope of Taxation
B. Residence
C. Determination of Gross Income
D. Allowable Allowances, Deductions and Credits
E. Rates and Calculation of Taxable Income
F. Assessment and Filing
G. Audit Process and Statute of Limitations for Assessment and Collection of Taxes
30:XI. Taxation of Nonresident Aliens
A. General
B. Business Income
C. Investment Income
1. Interest Income
2. Income from Distributed Profits
3. Income from the Rental of Real Property Located in Lithuania
4. Capital Gains
D. Method of Taxation
1. Business Income
2. Income Not Received Through a Fixed Base
30:XII. Estate/Inheritance/Transfer and Gift Tax
A. Estate, Inheritance or Transfers at Death Tax
1. Liable Persons
2. Taxable Base
a. Taxable Property
b. Exempt Transfers
c. Deductible Liabilities
d. Personal Allowances
3. Tax Rates
B. Gift Tax
30:XIII. Intercompany Pricing
A. Scope of the Provision
B. Determination of Arm's-Length Price
C. Documentation Requirements
D. Availability of Advance Pricing Agreements or Rulings on Pricing
E. Competent Authority
30:XIV. Special Provisions Relating to Multinational Corporations
A. Foreign Family Foundations
B. Tax Haven Operations
C. Controlled Foreign Corporations
30:XV. Avoidance of Double Taxation
A. Foreign Tax Credit or Exemption
B. Tax Treaties
1. Tax Treaty Negotiation and Ratification Process
2. Procedure to Claim Reduced or No Withholding, or Refund
3. Taxation of Business Income
a. Permanent Establishment
b. Industrial or Commercial Profits
c. Planning to Minimize Taxation of Business Income Under the Treaty
4. Taxation of Investment Income
a. What Is Investment Income?
b. Withholding Rates
C. Treaties with the United States
1. Income Tax Treaty
2. Estate and Gift Tax Treaty
3. Other

Working Papers

Table of Worksheets
Worksheet 1 Sample Articles of Association of a Limited Liability Company (OÜ)
Worksheet 2 Payroll Taxes
Worksheet 3 Withholding Tax for Payments to Non-resident Persons or Legal Entities
Worksheet 4 List Countries with Which Estonia Has In Force Income Tax Treaties and Other Tax-Related Agreements as of April 1, 2018
Worksheet 5 1998 Estonia-United States Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
Worksheet 11 Sample Articles of Incorporation for a Latvian LLC
Worksheet 12 Overview of Corporate Income Tax Calculation for Nonresidents
Worksheet 13 Residence Certificate to Claim Benefits under a Double Tax Treaty
Worksheet 14 List of Countries with Which Latvia Has In Force Income Tax Treaties and Other Tax-Related Agreements as of April 1, 2018
Worksheet 15 1998 Latvia-United States Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
Worksheet 21 Sample Articles of Association
Worksheet 22 Form DAS-1, Claim for Reduction or Exemption from the Anticipatory Tax Withheld at Source
Worksheet 23 Form DAS-2, Claim for Refund of the Tax Withheld at Source
Worksheet 24 Form DAS-3, Certificate of Income Received and Taxes Paid in the Republic of Lithuania
Worksheet 25 List of Countries with Which Lithuania Has In Force Income Tax Treaties and Other Tax-Related Agreements as of April 1, 2018
Worksheet 26 1999 Lithuania-United States Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income