Lithuania Transfer Pricing Documentation Requirements
Lithuania sets its Master File obligation at EUR 15 million of income and its Local File at EUR 3 million of revenue combined with intercompany transactions above EUR 90,000. A related-party transactions report, Form FR0528, is filed within six months and fifteen days of year-end.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Group member with income > EUR 15m in the preceding fiscal year | By the Master File deadline | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | Any (FI / EN in practice) | Yes (EUR 1,820 to EUR 5,590; higher for repeat offences) |
Local File Required | Revenue > EUR 3m and aggregate cross-border transactions > EUR 90,000 | By tax return due date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | Any (LT / EN in practice) | Yes (EUR 1,820 to EUR 5,590; higher for repeat offences) |
Form FR0528 Related-party report
Annual filing | Taxpayers with transactions between associated parties | 6 months and 15 days after fiscal year-end | Submission deadline The documentation must be filed with the tax authority by the date shown. | LT | Yes |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
A Lithuanian or foreign entity operating through a permanent establishment that belongs to an international group and has intercompany transactions must prepare a Master File where its income exceeds EUR 15 million in the year before the controlled transactions. The Local File is required where revenue exceeds EUR 3 million and aggregate cross-border intercompany transactions exceed EUR 90,000, and it is not required where no individual foreign controlled transaction, nor the sum of them, exceeds EUR 90,000. Documentation is produced within 30 days of a request.
Distinctive features of the Lithuanian regime
The defining feature of the Lithuanian regime is the per-transaction floor that gates the Local File alongside the revenue test. Even a taxpayer above the EUR 3 million revenue level is outside the Local File requirement where no individual foreign controlled transaction and no aggregate of them exceeds EUR 90,000, which focuses the obligation on entities with material cross-border dealings. The related-party report, Form FR0528, is filed within six months and fifteen days of the year-end. Penalties for non-compliance run from EUR 1,820 to EUR 5,590, rising for a repeated offence of the same kind, and a safe harbour applies to low-value-adding services as defined in the OECD Guidelines.
Benchmarking and comparables
Local practice follows the OECD Guidelines, with a preference for domestic comparables over foreign comparables, and foreign comparables used where no local comparables are found. Multi-year analysis is preferred as a matter of jurisdiction practice. The benchmarking results must be updated once every three years. Transfer pricing assessments may apply to the five years before the year in which the assessment takes place.
Frequently asked questions
Can a Lithuanian taxpayer above the revenue threshold still avoid the Local File?
Yes. The Local File is not required where no individual foreign controlled transaction, and no aggregate of them, exceeds EUR 90,000, even if revenue is above the EUR 3 million threshold.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.