Data points
- Group income that triggers a master file[2]
- EUR 15m
- Entity turnover that triggers a local file[2]
- EUR 3m
- Per associated person value below which no local file documentation is needed[2]
- EUR 90,000
- To produce both files once the tax inspectorate asks[2]
- 30 days
- Top of the first-offence personal fine on the company's manager[2]
- EUR 5,590
- Shares, votes or asset use rights above which two parties are associated[1]
- 25%
Lithuania keeps both files on the shelf. Nothing goes in proactively, the documentation fine falls on a person rather than the company, and the clock that matters starts the day the tax inspectorate asks.
The four facts to know:
- A master file is required once the group's income passes EUR 15 million in the preceding tax period.
- A local file is required once the Lithuanian entity's turnover passes EUR 3 million in the previous tax year. Financial undertakings, credit institutions and insurers prepare one at any size.
- Both must be ready by the 15th day of the sixth month after the tax period, which is 15 June for a calendar year taxpayer, then produced within 30 days of a request.
- A manager who cannot produce them pays a personal fine of EUR 1,820 to EUR 5,590, rising to EUR 3,770 to EUR 6,000 on a repeat.
Who needs transfer pricing documentation in Lithuania?
The Lithuanian entity carries the obligation: a subsidiary of a foreign group, or a Lithuanian permanent establishment of a foreign company. The foreign parent is on the hook indirectly, because the master file is a group document it usually prepares and the local file describes transactions it is party to.
Two companies are associated persons when one controls, directly or indirectly, more than 25% of the shares, decisive votes or asset use rights of the other, under the corporate income tax law published in the register of legal acts[1]. The thresholds and the documentation rules themselves are set out in the OECD transfer pricing country profile for Lithuania[2], updated July 2025.
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| Obligation | Threshold | Tested against | Source |
|---|---|---|---|
| Master file | Group income above EUR 15 million | The preceding tax period | OECD |
| Local file | Turnover above EUR 3 million | The previous tax year | OECD |
| Local file for financial undertakings, credit institutions and insurers | No size threshold | Any year | OECD |
| Per transaction exemption | Value below EUR 90,000 per associated person | Each tax period | OECD |
| Associated persons test | More than 25% of shares, votes or asset use rights | Not applicable | Register of Legal Acts, Lithuania |
Do you need a master file in Lithuania?
Only if your Lithuanian entity belongs to an international group whose income exceeded EUR 15 million in the preceding tax period. Foreign companies with a Lithuanian permanent establishment are in scope on the same test. Below that income level, no master file is required at all.
The test looks at the period before the one in which the controlled transactions happened. For a calendar year taxpayer documenting 2026 transactions, it is the 2025 income figure that decides the obligation. The content follows the standard group structure, business description, intangibles, intercompany financing and group financial and tax positions.
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Do you need a local file in Lithuania?
Yes, if the Lithuanian entity's turnover exceeded EUR 3 million in the previous tax year. Financial undertakings, credit institutions and insurers prepare one regardless of turnover. The file covers the local entity, its controlled transactions and the financial data behind them.
Two carve-outs narrow it. A controlled transaction below EUR 90,000 with one associated person in a tax period needs no local file documentation. Transactions only with other Lithuanian entities or permanent establishments are exempt as well.
How does the EUR 90,000 exemption actually work?
It has three exceptions, and each of them catches groups out. Several identical transactions with the same associated person that together top EUR 90,000 are documented. A transaction inextricably linked to another, so that their combined value tops EUR 90,000, is documented. And any transaction with a counterparty in a targeted territory carries no threshold at all.
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| Local file rule | Value | Tested against | Source |
|---|---|---|---|
| Turnover trigger | Above EUR 3 million | The previous tax year | OECD |
| Financial firms | No size exemption | Any turnover | OECD |
| Per transaction exemption | Below EUR 90,000 per associated person | Each tax period | OECD |
| Targeted territory counterparty | No threshold | Every transaction | OECD |
Does Lithuania require country-by-country reporting?
Yes. The report is due within 12 months after the last day of the reporting financial year, and the notification identifying the reporting entity is due by the last day of that fiscal year. It is a group level filing, separate from the master file and the local file.
The consolidated revenue threshold that brings a group into scope is not confirmed, because the country profile states no Lithuania specific figure. Confirm it with the State Tax Inspectorate[3] before you rely on a number from elsewhere.
Does Lithuania have a transfer pricing return?
Yes, a return on controlled transactions exists, filed separately or annexed to the tax return. Its exact name, the threshold that triggers it and its deadline are not confirmed, so this page states none of them.
Treat the documentation obligation above as the governing rule and check the form details with the tax inspectorate. Nothing about the master file or local file deadlines depends on it.
When is Lithuania transfer pricing documentation due?
Prepared, not filed. The master file and local file must be ready by the 15th day of the sixth month of the following tax period, which is 15 June for a calendar year taxpayer, then submitted within 30 days of a request. The 30 day window is the clock that actually bites.
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| Obligation | Deadline | Source |
|---|---|---|
| Master file and local file prepared | 15th day of the sixth month after the tax period | OECD |
| Master file and local file on request | Within 30 days of a request | OECD |
| Country by country report | Within 12 months after the reporting financial year end | OECD |
| Country by country notification | By the last day of the reporting fiscal year | OECD |
What language must the documentation be in?
Any language you choose, until the tax inspectorate asks. On request the documentation is provided in its original language, and the inspectorate may then require a Lithuanian translation. In practice that means English is fine for the master file day to day, with a translation produced on demand. Lithuania has used the euro since 2015, so every threshold is a euro figure.
What are the penalties for getting Lithuania transfer pricing wrong?
The documentation fine is personal. A breach of the documentation rules is an administrative fine on the company's manager of EUR 1,820 to EUR 5,590, rising to EUR 3,770 to EUR 6,000 for a repeat offence. It is charged to the individual, not the company.
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| Offence | Fine on the manager | Source |
|---|---|---|
| First violation | EUR 1,820 to EUR 5,590 | OECD |
| Repeat violation | EUR 3,770 to EUR 6,000 | OECD |
The fine is the smaller risk. The real exposure is adjustment: the tax inspectorate can reset the entity's profits to arm's length and assess the underpaid tax with interest, for the current tax period plus the five preceding ones. That five year reach is why files are kept long after the preparation deadline passes.
Can you get an advance pricing agreement in Lithuania?
Yes. Unilateral, bilateral and multilateral agreements are all available, alongside the mutual agreement procedure for resolving disputes after the fact. A bilateral agreement is what takes double taxation off the table before an adjustment can create it.
Lithuania also allows a simplified approach for low value-adding intra-group services, following the OECD treatment of them. On comparables it states no preference between domestic and foreign data, which is unusual and helpful: a pan-regional set needs no special defence.
How we help with Lithuania transfer pricing
Lithuania's 30 day window assumes a file that is already finished and already translatable, and the fine lands on a named person if it is not. We build the benchmarking and the functional analysis, draft the master file and the local file against the EUR 15 million and EUR 3 million tests, and keep them current rather than rebuilt each spring. See how our transfer pricing software works.
Book a demo to find out exactly which files your Lithuanian entity owes for 2026.
Official sources
3 sources
- 1.Register of Legal Acts, Lithuania. Law on Corporate Income Tax, consolidated text
- 2.OECD. Transfer pricing country profile: Lithuania (July 2025)
- 3.State Tax Inspectorate, Lithuania. State Tax Inspectorate (official site)
Article by
Logan Jackonis
Head of Services & Operations, Commenda
Logan leads Commenda’s Services and Operations team, helping controllers, heads of tax, and finance leaders navigate international expansion. He built a global expert network across 70 countries and previously worked in management consulting across the Middle East and Southeast Asia.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
