Lithuania

Transfer Pricing in Lithuania

Lithuanian transfer pricing (sandorių kainodara) in tax year 2026. It covers associated persons (asocijuoti asmenys) and related persons under Corporate Income Tax Law art. 2(8) and 2(33), the arm's length rule in art. 40(1) and (2), the Minister of Finance rules approved by Order No. 1K-123 (methods, the arm's length range and the median, low value-adding services at cost plus 5%, hard-to-value intangibles), documentation (master file above EUR 15 million revenue in a group, local file above EUR 3 million, the EUR 90,000 transaction exemption, 30 days to hand it over), the FR0528 related-party report, advance pricing agreements under Tax Administration Law art. 37-2, country-by-country reporting (EUR 750 million), the 5-year reassessment window, fines of 20% to 100% and late payment interest.