Taxation, real costs, formation steps and a comparison of European jurisdictions. Everything you need to know before deciding.
A holding company's main purpose is to hold shares in other companies (subsidiaries). In Latvia, the preferred legal form for a holding is the SIA (Sabiedrība ar ierobežotu atbildību), the equivalent of a limited liability company.
A Latvian holding is particularly attractive for international entrepreneurs because it combines two rare advantages: EU membership, with everything that implies in terms of legal rights, directives and credibility, and a unique tax regime where corporate tax is only due when profits are distributed, not when they're earned.
Typical structure of a Latvian holding with EU subsidiaries
Latvia applies every relevant EU directive: the parent-subsidiary directive, the interest and royalties directive, OECD BEPS standards. Your holding operates within a legal framework recognised and respected across Europe.
Many entrepreneurs arrive at this topic having searched for an "offshore company in Latvia". That's an understandable shortcut: Latvia's tax regime is attractive, structure costs are low, and remote formation is possible. But a Latvian SIA holding isn't an offshore structure in the classic sense, it's a regulated European company, subject to OECD standards, whose tax advantage rests on a legal mechanism recognised by every EU member state.
The Latvian regime works on a cash-flow tax principle: as long as profits stay in the company, no corporate tax is levied. The 20% rate only applies when dividends are distributed to shareholders. For a holding whose goal is to accumulate capital and reinvest, that's an exceptional tax position.
As a company established in an EU member state, a Latvian SIA holding automatically benefits from Directive 2011/96/EU (the parent-subsidiary directive). In practice, dividends flowing up from a subsidiary established in another EU country to the Latvian holding are exempt from withholding tax, under two conditions:
Latvia has signed double-tax treaties with more than 60 countries, which govern how double taxation is avoided. As an example, dividends paid from a French subsidiary to a Latvian holding are subject to a withholding tax of 5% (for a stake of 10% or more) or 15% (in other cases) under the France-Latvia treaty. If your subsidiaries sit in a different country, check that specific treaty's terms with a qualified advisor.
Dividend flows and achievable tax savings through a Latvian holding
Before choosing Latvia, it's worth comparing the main alternatives. Here are the decisive criteria:
| Criterion | Latvia |
🇳🇱 Netherlands | 🇱🇺 Luxembourg | Ireland |
🇫🇷 France |
|---|---|---|---|---|---|
| Effective holding CIT rate | 0% (reinvested) | 25.8% | 17% | 12.5% | 25% |
| Dividend participation exemption | 100% (EU) | 95% | 100% | 100% | 95% |
| Minimum capital | €2,800 | €1 | €12,000 | €1 | €1 |
| Formation time | 3–7 days | 5–10 days | 2–4 weeks | 3–5 days | 8–15 days |
| Annual accounting cost | €1,200–3,600 | €8,000–20,000 | €10,000–25,000 | €5,000–15,000 | €2,000–6,000 |
| Economic substance required | Yes (OECD) | Yes (strict) | Very strict | Yes | Yes |
| EU member | Yes | Yes | Yes | Yes | Yes |
Latvia stands out for combining one of Europe's lowest structure costs with a tax regime built on deferred distribution. Luxembourg and the Netherlands offer comparable advantages, but with substance requirements and maintenance costs that are significantly higher.
The SIA's name must be unique. Availability is checked online with the Latvian Enterprise Register (UR). Avoid regulated terms (bank, insurance, fund).
The articles (SIA dibināšanas līgums) must set out the company's purpose, shareholders, capital allocation and the director's powers. Non-residents can sign via a notarised power of attorney.
The €2,800 capital must be paid into a Latvian bank account opened in the future company's name, before registration. Proof of transfer is required.
The file is submitted online or in person to the UR. Official fees range from €20 to €140 depending on the route chosen. Registration takes 3 to 7 business days.
Mandatory for any intra-EU transaction. The application is filed with the State Revenue Service (VID) alongside or after registration. Timeframe: 1 to 5 days.
Latvian law requires appointing a licensed accountant. All transactions must be recorded from day one of activity. The annual close is filed before 30 April.
One of Latvia's decisive advantages is how transparent and modest the costs are. Here are the real 2026 figures:
Formation (one-off): €500–1,500 (UR fees + formation fees)
Annual accounting: €1,200–3,600 depending on volume and complexity
Registered address: €200–600/year
Annual audit (if required): €800–2,500
Total annual maintenance: €1,500–5,000
Holding structuring: good European tax practices
Non-residents, whether EU or non-EU nationals, can set up and run a SIA holding from abroad. There's no residency requirement for the director or the shareholders.
An entrepreneur based in Paris, Geneva or Toronto can own 100% of a Latvian SIA holding and run its effective management remotely. A notarised power of attorney and electronic signature let you handle every formality without travelling.
That said, for the structure to hold up under a tax audit, effective management genuinely needs to happen from Latvia (or be delegated to a local representative). A registered address alone isn't enough to establish economic substance.
Following the OECD's BEPS recommendations, a holding with no real substance (staff, premises, decisions made locally) risks being reclassified. Your home country's tax authority may challenge the reality of effective management and tax the income at home under its own anti-abuse rules, for French residents, for example, under Article 209 B of the French tax code.
Many countries apply CFC-style rules: if you're a tax resident who owns more than 50% of a foreign holding whose income is mostly "passive" (dividends, interest, royalties), your home tax authority may apply transparency rules and tax that income directly at home, even if it hasn't been distributed. Check your own country's specific CFC rules before structuring around Latvia.
Dividends paid by the SIA holding to an individual shareholder are subject to a 20% withholding in Latvia (creditable against home-country income tax under an applicable treaty). Factor this cost into your overall assessment of the structure's efficiency.
This guide would be incomplete without this section. Latvia isn't a universal solution. Here are situations where another jurisdiction would fit better:
Our experts review your existing structure and tell you whether Latvia is the right option, or which alternative to consider.
Free Consultation Learn More About the SIACIT rate, dividend taxation, the 2026 alternative regime, VAT, double-tax treaties: our complete guide to SIA taxation.