Transfer Pricing

Our Services

Preparation of transfer pricing documentation and benchmarking studies

  • Lithuanian companies with an annual turnover of over EUR 3 million must prepare the transfer pricing documentation

  • We prepare transfer pricing documentation and benchmarking studies for various inter-company transactions between associated parties

  • Based on your needs, we can prepare the transfer pricing documentation in comply with foreign country‘s transfer pricing requirements and practice

Preparation of the transfer methodology/policy

  • We prepare transfer pricing methodology/policy to determine the arm‘s length pricing

Representation in tax disputes with the Tax Authority

  • We consult and represent taxpayers at all stages of tax-related disputes

  • We prepare responses/explanations to tax administrator’s requests

  • We participate in meetings and negotiations or help to prepare for meetings and negotiations with the tax administrator

Preparation of Country-by-Country report

Multinational (MNE) groups of companies with a consolidated group annual turnover of over EUR 750 million in a financial year, are required to submit a yearly Country-by-Country Report (CbCr) to the Tax Authority. The County-by-Country Report should include the net turnover earned from related and third parties in every tax jurisdiction, corporate income tax paid (including withholding tax), stated capital, number of employees and other information. 

PwC’s specialists can help:

  • To prepare a CbC report notification to the Tax Authority

  • To assist in preparing a CbC report

  • To assess transfer pricing risks by using a number of financial ratios

Preparation of advance pricing agreements with the Tax Authority

We help to prepare an application for advance pricing agreement (APA) with the Lithuanian Tax Authority on the applicable principles of the transfer pricing. Benefits of advance pricing agreement:

  • It is extremely useful for companies that are going to conclude a complex controlled transaction for which it is difficult to find a comparative data;
  • It helps to reduce transfer pricing risks for a 5-year period;
  • It minimizes the costs of preparing the transfer pricing documentation.

Why PwC?

Professional team

PwC has been offering the transfer pricing services in Lithuania for over 10 years. The transfer pricing team in Lithuania consists of about 10 specialists, who have accumulated extensive experience and can help you to implement the most complex projects. 


Cooperation with the Tax Authority

PwC constantly cooperates with the Lithuanian tax administrator and participates in tax disputes. This experience enables us to provide high quality PwC’s services and offers solutions to clients in accordance to the latest trends in the tax administrator’s practice.

Specific Transaction Analysis

We have many years of extensive experience in implementing complex projects that require high qualifications, experience and specific databases or tools, for instance by determining the pricing of financing, licensing, patent sales and other transactions. 


Our internal (TP-AI CUT) and external (e.g. Amadeys, TP Catalyst, DealScan, RiskCalc) databases provide access to the financial information we use to prepare benchmarking studies for various transactions. 

Internal tools

We use internal tools (e.g. GCD reporter, CbC Analyzer), which contribute to the rapid and efficient analysis of information and preparation of transfer pricing documentation.

Follow us