Clearly no legislation can ever cover all circumstances and needs to be interpreted case-by-case. This is especially true in an economy like Lithuania which is changing more rapidly than some areas in the law. We assist in the interpretation process, sharing with you our experience of practice, case law, tax authority and ministry opinions in order to arrive at a position which reflects the indicated propensity for tax cost saving and risk.
Other corporate tax assistance involves performing reviews aimed at highlighting areas of increased tax risk or opportunities for saving. A variation on this involves reviewing tax policies and controls in more detail than a statutory audit to advise on areas which may have been superseded by legislation or which may be unclear enough to engender unintended tax risk.
Legislation change is a part of doing business in Lithuania as is the fact that inspectors are continually refining their approaches to many issues, for example following major tax audits, participation in information exchange or cross-border training programs. We therefore periodically release bulletins and invite participation in seminars to share our practical experience with you.
For new investors, our international reach allows us to propose structuring which includes intermediary or base entities for the purpose of double tax treaties, ensuring that advice on scope of CFC rules as well as tax deferral options. We assist in-house tax departments in fine-tuning structures to take account of Lithuania-specific variations on standard rules, such as for reorganizations or arm’s length gearing ratios for thin capitalization.