Tag: Joint control
Legal test determining whether two or more persons collectively exercise decisive influence over an entity, triggering related-party status under transfer pricing rules. Tax authorities challenge equal shareholding arrangements as joint control, though courts often require more than mere equal influence to establish th.
Latvia vs SIA „Woodison Terminal”, June 2018, Supreme Court, A420437112, SKA-97/2018
A Latvian company faced a tax authority challenge over whether equal shareholder influence constituted joint control triggering transfer pricing rules under Section 12(2) of the Corporate Income Tax Act. The Supreme Court ruled in favour of the taxpayer, finding that equal influence does not automatically imply decisive influence or joint control, and that specific circumstances must be identified to establish concerted action ... Read more