  		  As of January 1, 2019, there are two CFC rules in Latvia.     1) CFC rule from the EU Council Directive 2016/1164 (ATAD) applicable to companies;     2) CFC rule applicable to natural persons.         The CFC rule in the CIT Law (Article 6   1   ) provides the definition of non-genuine arrangements, participation threshold, and limitation to apply CFC rule. The CFC is defined as a permanent establishment or an entity if the taxpayer by itself, or together with its associated enterprises holds a direct or indirect participation of more than 50 percent of the voting rights, or owns directly or indirectly more than 50 percent of capital or is entitled to receive more than 50 percent of the profits of that entity. CFC rule applies only in case of CFC’s income arising from non-genuine arrangements that have been put in place for the essential purpose of obtaining a tax advantage. An arrangement or a series thereof shall be regarded as non-genuine to the extent that the entity or permanent establishment would not own the assets or would not have undertaken the risks which generate all, or part of, its income if it were not controlled by a company where the significant people functions, which are relevant to those assets and risks, are carried out and are instrumental in generating the controlled company's income.          The CFC rule in the PIT Law (effective starting from 2013) is applicable to natural persons (article 17   3    of the law in Personal income Tax)  if at least 25% of a non-resident capital company (the stocks of which are not quoted in the regulated market of a European Union Member State or European Economic Area State  )  , partnership or other legal person, a foreign foundation, trust or other legal entity set or established low tax or no tax countries and territories is owned or controlled, directly or indirectly, by resident taxpayers (individuals).  In this case profits of such company, partnership, person, foundation, trust or entity, whether distributed or not, are attributed proportionately to their resident shareholders and taxed accordingly (under individual income tax). The list of low tax or no tax countries and territories is governed by the Cabinet of Ministers (Regulations of the Cabinet of Ministers dated of June 27, 2023 (No.333).  