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.