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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Latvia: Residence

Where a person other than an individual (for example a company) is resident in both Latvia and in the United Kingdom under the countries’ respective domestic laws, the agreement provides that the competent authorities of the countries shall endeavour to settle the question of residence for the purposes of the treaty by mutual agreement, having regard to such factors as the place of effective management, the place of incorporation or constitution and any other relevant factors (see Article 4(3) and paragraph 2 of the Exchange of Notes).

Any such cases should be referred to Business International.