SolvedDT11753 | Double Taxation Relief Manual: Latvia: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Latvia is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 15% | 10 |
| Dividends on direct investments | 5% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which controls directly at least 25% of the voting power in the company paying the dividends | 10 |
| Property income dividends | 15% | 10 |
| Interest | 10% (Note 1) | 11 |
| Royalties | 5/10% (Note 2) | 12 |
| Government pensions | Taxable only in Latvia unless the individual a resident and national of the UK | 19 |
| Other pensions | Taxable only in the UK | 18 |
| Arbitration | No | N/A |
Note 1: Interest paid in the following circumstances is exempt from tax in Latvia:
where the payer is the Latvian Government, a political subdivision or a local authority thereof or an agency or instrumentality of the Latvian Government, political subdivision or local authority
where the recipient is the UK Government, a political subdivision or a local authority thereof or an agency or instrumentality of the UK Government, political subdivision or local authority
where the interest is paid in respect of a loan made, guaranteed or insured, or any other debt-claim or credit guaranteed or insured by the UK Export Credits Guarantee Department or by the state joint stock company "Latvian Exportcredit" (Latvijas eksportkredits) or by any organisation established in either Latvia or the UK after the date of signature of this Convention and which is of a similar nature
where the interest is paid in respect of a loan made, guaranteed or insured by the Bank of England or the Bank of Latvia
Note 2: The lower rate of 5% applies only to the gross amount of royalties that are for the use of industrial, commercial or scientific equipment. The 10% rate applies to all other royalties.