The Lithuanian Tax Authority adopted procedural guidelines, effective January 1, 2012, pertaining to advance pricing agreements (APAs). Based on the new rules, an application for an APA may be submitted only by a Lithuanian taxable person (a company or an individual) or its representative. An APA application, which initiates the negotiation, should include justification for the agreement and background information about the transactions covered, in addition to details about each entity’s business strategy, risk assumed, and assets employed. The taxpayer must also describe the chosen transfer pricing method, explain the comparable analysis and critical assumptions used in the application of the selected transfer pricing method, as well as demonstrate compliance with the arm’s length standard. Tax authorities are required to review and issue a decision on the APA request within 60 to 120 calendar days.

Related Links:
(a) PKN Alert
(b) T Magazine