Transfer Pricing

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

• 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

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

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.