DT11754 - Double Taxation Relief Manual: Guidance by country: Latvia: Notes

Independent Personal Services (Article 14)

Income derived by a UK resident in respect of professional services or other activities of an independent character are taxable only in the UK unless the individual has a fixed base regularly available to them in Latvia.

For this purpose, where an individual’s stay in Latvia exceeds 183 days in any twelve month period, they are deemed to have a fixed base regularly available to them in Latvia. In these circumstances, Latvia is permitted to tax the income attributable to the fixed base or to the activities performed in Latvia, as the case may be.

Artistes and sportsmen (Article 17)

Where an entertainer or sportsperson, who is a resident of one country, visits the other country and performs activities there, that other country may tax any income derived from those activities unless the visit is one which is wholly or mainly supported by public funds of the country of residence of the entertainer or sportsperson, (Article 17(3)).

Professors and Teachers (Article 21)

Article 21 provides that a visiting teacher from Latvia will be exempt from UK tax on their remuneration from teaching or research at a university, college or other recognised educational institution, for a period not exceeding two years from the date of their first visit to the UK for that purpose (Article 21(1)).

The Article only applies, in the case of research, where the research is undertaken in the public interest (Article 21(2)).