Corporate - Significant developments

Last reviewed - 13 July 2021

Amendments to the tax laws

The following amendments to the Laws on corporate income tax (CIT), personal income tax (PIT) and social security contributions (SSC) entered into force as of 1 January 2021.

Corporate income tax (CIT)

A new corporate income tax (CIT) relief has been recently introduced in Lithuania, i.e. large projects relief that came into force from 1 January 2021.

    Based on the provisions of the Lithuanian Law on CIT, revenue an entity earned in a course of carrying out a large investment project may be exempt from CIT for a period of 20 years (or until the maximum state aid is reached). The requirements for the application of the relief are the following:

    • the average number of employees involved in the implementation of a large project in Lithuania during the tax year should not be less than 150 (200 if business is established in Vilnius or its district);
    • capital investment of the entity should be not less than EUR 20 million (EUR 30 million if business is established in Vilnius or its district), and an auditor’s confirmation on the actual amount of capital investment is required;
    • at least 75% of the entity’s revenue should consist of revenue from (i) manufacturing, (ii) data processing, or (iii) internet server services (hosting) and related activities.
    • an investment agreement with the government of the Republic of Lithuania is required.

    In order to benefit from large projects relief, all above listed requirements shall be met jointly, and the relief starts to apply from the tax period when the thresholds are reached. The application of the relief is suspended for the tax periods in which the amount of capital investment and / or the average number of employees falls below the required threshold. The exemption will be renewed for the tax period when the required thresholds are reached again. Moreover, the exemption will not be granted to companies established in and benefiting from the preferential taxation in Free Economic Zone.

    Payroll taxes

    Starting from 1 January 2021, the threshold when the higher PIT rate is applicable decreased for employment related income from EUR 104,278 per calendar year to EUR 81,162. A 32% PIT rate for the income exceeding this threshold is applied.

    Social security contributions (SSC)

    Starting from 1 January 2021, the ceiling for SSC withholding decreased from EUR 104,278 to approximately EUR 81,162 per calendar year. 

    Other significant amendments

    Transfer pricing

    Starting from 1 January 2020, transfer pricing documentation requirements are not applicable to controlled transactions of a Lithuanian entity or a foreign entity operating through a permanent establishment in the Republic of Lithuania that are concluded with another Lithuanian entity or a foreign entity operating through a permanent establishment in the Republic of Lithuania, a permanent resident of Lithuania and / or a non-permanent resident of Lithuania carrying out individual activities under a business certificate on a permanent basis, if such transactions are related to their activities in Lithuania.

    DAC6 implementation

    The European Union (EU) Directive on the mandatory disclosure and exchange of reportable cross-border tax arrangements (referred to as DAC6 or the Directive) has been introduced into Lithuanian law. Under DAC6, taxpayers and intermediaries are required to report cross-border reportable arrangements from 1 January 2021.