Share with your friends

Lithuania: New transfer pricing documentation requirements in 2019

Lithuania: Transfer pricing documentation requirements

New transfer pricing documentation requirements apply in Lithuania beginning in 2019.


Related content

The new transfer pricing documentation requirements were introduced 31 December 2018, and apply to related-party transactions conducted in 2019 and subsequent years. The new requirements generally reflect measures implementing recommendations under the OECD’s base erosion and profit shifting (BEPS) project.

Among the measures relating to the transfer pricing documentation rules are the following:

  • The definition of a “group of entities” has been expanded.
  • There are new turnover thresholds. The taxpayer will be required to prepare the:
    • Master file – if turnover exceeds €15 million and the taxpayer is part of an international group
    • Local file – if turnover exceeds €3 million
  • Exemptions for low-value transactions have been introduced. Transfer pricing documentation will not be required if a controlled transaction or the sum of controlled transactions during the financial year does not exceed €90,000 per related party.
  • Deadlines for preparing transfer pricing documentation have been set. The documentation must be prepared by the 15th day of the sixth month after the financial year-end.
  • Updates of transfer pricing documentation can be made every three years if the conditions and circumstances of the underlying transactions remain unchanged. The data of controlled transactions must be updated annually.
  • Sanctions for non-compliance with new requirements have been tightened. Non-compliance with the transfer pricing documentation requirements will result in a penalty ranging from €1,820 to €5,590, and the penalty for repeated violations will range from €3,770 to €6,000.


For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice in Lithuania:

Giedrius Biconas | +370 5 210 2600 |

© 2020 Copyright owned by one or more of the KPMG International entities. KPMG International entities provide no services to clients. All rights reserved.

KPMG refers to the global organization or to one or more of the member firms of KPMG International Limited (“KPMG International”), each of which is a separate legal entity. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. For more detail about our structure please visit

Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal