Page 39 - Central and Eastern European Transfer Pricing Review

Lithuania | 39

companies having substantial volume Are year-end transfer pricing Advance pricing
in international transactions. The adjustments permitted? arrangements
transactions subject to an increased No.
scrutiny are: fnancial transactions, What APA options are available, if
royalty payments and intra-group Other unique attributes? any?
services (particularly management Not applicable. Unilateral and bilateral.
services).
Is there a fling fee for APAs?
Other recent
Special considerations developments No.
Are secret comparables used by As of 1 January 2012 it is possible to Does the tax authority publish APA
tax authorities? data either in the form of an annual
apply for an APA. Changes to the transfer
Yes, the tax authorities can use pricing rules have been initiated. In May report or through the disclosure of
comparables which are not disclosed 2013, the Conference of Ministers of data in public forums?
to the taxpayer. the OECD will be deciding about the No information yet.
membership of Lithuania.
Is there a preference, or requirement, Please provide some information
by the tax authorities for local on how successful the APA program
comparables in a benchmarking set? Tax treaty/double tax is and whether there are any known
No. resolution diffculties?
What is the extent of the double tax No information yet.
Do tax authorities have requirements
or preferences regarding databases treaty network? Language
for comparables? Extensive. Currently, Lithuania has
49 double tax treaties.
No. In which language or languages
can documentation be fled?
If extensive, is the competent
What level of interaction do tax Documentation can be prepared in any
authorities have with customs authority effective in obtaining language but it must be translated into
authorities? double tax relief? Lithuanian at the request of the tax
No experience (in transfer pricing cases).
High. authorities.
Are management fees deductible? When may a taxpayer submit an
adjustment to competent authority?
Generally, yes.
No formal rules.
Are management fees subject to
withholding? May a taxpayer go to competent
authority before paying tax?
No.
Not permitted.

KPMG in the Baltics

Biruté Petrauskaité
Tel: +370 5 2 102 613
Email: bpetrauskaite@kpmg.com

As email addresses and phone numbers
change frequently, please email us at
transferpricing@kpmg.com if you are unable
to contact us via the information noted above.
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