How to Appeal a VID Decision in Latvia

You open a VID decision letter and disagree with the assessment. Maybe the auditor misinterpreted a transaction. Maybe the penalty seems disproportionate. Maybe the entire audit was based on flawed assumptions. Whatever the reason, Latvian law gives you a clear two-stage appeal path — but the deadlines are strict, and missing them forfeits your right to challenge the decision entirely.

Roughly 15-20% of VID audit decisions are formally appealed each year. Of those that reach the Administrative Court, taxpayers succeed (fully or partially) in approximately 30-40% of cases. Those are meaningful odds — but only if the appeal is grounded in substance, not frustration.

Stage 1: Appeal to VID Senior Official

Your first step is an internal appeal — a written objection submitted to a senior VID official (typically the head of the relevant VID department or the Director General, depending on which office issued the decision).

Deadline: 30 calendar days from the date you received the decision. Not 30 business days. If the decision arrived on March 5, the appeal must be filed by April 4. Late appeals are rejected without review.

What to include:

• Your identification (company name, registration number, tax identification number)
• The specific decision you are appealing (decision number, date, issuing officer)
• The grounds for your appeal — which facts or legal conclusions you dispute and why
• Supporting evidence: documents, calculations, legal references, expert opinions
• Your requested outcome (annulment, reduction, modification)

VID's response timeline: VID must issue a decision on your appeal within 30 days (extendable to 60 in complex cases). During this period, the appealed decision is typically not enforced — meaning VID should not freeze accounts or seize assets while the internal appeal is pending. (If VID does attempt enforcement during an appeal, you can request a court injunction.)

The strategic value of Stage 1: Even though VID overturns its own decisions less frequently than courts do, the internal appeal serves two purposes. It forces VID to formalize its legal reasoning (which sometimes reveals weaknesses), and it creates a complete administrative record that strengthens your position if you proceed to court.

Stage 2: Administrative District Court

If VID rejects your internal appeal (or you are unsatisfied with the outcome), you can file an application with the Administrative District Court.

Deadline: 30 calendar days from the date you received VID's response to your internal appeal. You must have completed Stage 1 first — the court will not accept direct applications that bypass VID's internal review.

Court process:

• File your application at the Administrative District Court (Administratīvā rajona tiesa)
• Court fee: EUR 30 for natural persons, EUR 70 for legal entities (modest by any standard)
• The court reviews the case on its merits — it can examine new evidence and is not bound by VID's factual findings
• Timeline: 6–18 months for a first-instance decision, depending on complexity
• Further appeals to the Administrative Regional Court and the Supreme Court Senate are possible but take additional years

Should you pay the disputed amount while appealing? This is a judgment call. Late payment interest (0.05%/day) continues to accrue during the appeal. If you lose after 12 months, you will owe the original tax plus penalties plus approximately 18% in accumulated interest. Some companies pay the disputed amount under protest and seek a refund if they win — eliminating interest risk but tying up cash.

When an Appeal Makes Sense

Not every unfavorable VID decision warrants an appeal. Weigh these factors:

• Legal merit: Is there a genuine legal argument, or do you simply dislike the outcome? Courts distinguish between VID applying the law incorrectly and VID applying the law in a way you find burdensome.
• Financial stakes: The cost of professional representation (EUR 2,000–15,000 for court proceedings) must be proportionate to the disputed amount.
• Precedent risk: An appeal that fails can set a negative precedent for your future interactions with VID.
• Interest exposure: Every month of litigation adds 1.5% to your obligation if you lose.

In our experience at CORVUS, the strongest appeal cases involve VID applying incorrect legal interpretations, using flawed audit methodology, or failing to consider evidence that the taxpayer provided during the audit.

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Not every VID assessment is correct, and not every appeal is worth pursuing. We evaluate the merits of your case, draft the internal objection with supporting documentation, and represent you through Administrative Court if needed. The initial assessment is free -- you only proceed if the numbers justify it.

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