Sanctions and risks of non-compliance with transfer pricing obligations

Absence of transfer pricing documentation:

• 30 days term for submission;
• If not submitted – possible fine from 1400 to 4300 Eur (from 2016-04-01).

Non-compliance with disclosure obligation:

• If not submitted  – possible fine from 150 to 300 Eur (from 2016-04-01).

Non-compliance with market prices:

• Fines – 10-50% of the amounts of unpaid taxes and late payment interest (0,03%/day);
• Periods of possible tax audit – current year and five last years;
• Lithuanian tax authorities are able to recalculate transactions prices.