BALTIC TAX CENTRE / NEWS & INSIGHTS

OCTOBER 2026

Monthly Updates.

Selected Lithuanian tax legislation, official guidance and dispute decisions, including one Tax Disputes Commission ruling from September.

New reporting requirements for Lithuanian investment accounts

On 16 October 2026, the Lithuanian State Tax Inspectorate (STI/VMI) adopted Order No. VA-69 amending the rules for declaring an investment account and reporting the income received through it. The order took effect on 17 October 2026.

The revised paragraph 13 specifies that a Lithuanian resident must notify the tax authority of an account designated as an investment account after the end of the tax year, no later than 1 May of the following year. The order expressly provides that this rule applies when calculating and declaring personal income tax for 2025 and subsequent tax years.

A new paragraph 19.3 requires information on proceeds from sales of financial instruments and/or interest received through the investment account. This addition applies to personal income tax returns for 2026 and later years. The order also updates the provisions on processing and retaining taxpayer data.

Lithuania proposes extending the shipping tonnage tax regime through 2036

A draft amendment to Articles 2 and 38¹ of the Lithuanian Law on Corporate Income Tax, registered in October 2026, proposes to continue the special fixed corporate income tax regime for qualifying maritime shipping companies until 31 December 2036.

Under the tonnage tax regime, qualifying shipping income is taxed by reference to prescribed vessel tonnage measures rather than the company's actual accounting profit. The currently consolidated text of Article 38¹(5) provides for the regime to apply until 31 December 2026; the draft would replace this end date with 31 December 2036.

The draft would also amend the treatment of bareboat charter out arrangements. The existing rules impose conditions concerning the three-year duration of rental income, temporary surplus tonnage and the purpose for which a vessel was acquired or chartered. The proposal provides that these conditions would not apply when a vessel is chartered without crew to another shipping company in the same group.

As of October 2026, the proposal has not been enacted. According to the explanatory memorandum, the purpose is to maintain the competitiveness of Lithuania's shipping sector and provide a stable tax framework. The memorandum reports that the European Commission approved the extension and amendment under State aid decision C(2026) 5842 of 13 August 2026. The proposal also includes transitional filing arrangements for shipping companies first electing the regime for a tax period beginning in 2027.

VAT and excise relief rules expanded for international defence cooperation

On 28 October 2026, the Lithuanian Government adopted Resolution No. 808 amending the rules governing VAT and excise relief for goods and services supplied in the field of international relations. The resolution is scheduled to take effect on 1 December 2026.

The amended rules expressly cover suppliers of goods and services identified in Lithuania's ratified international defence treaties and implementing arrangements. They also address persons that have entered into contracts or other arrangements with the specified suppliers, service providers or foreign armed forces for the activities covered by those agreements.

For eligible persons, the relief can be applied directly at the point of supply or by refunding VAT and/or excise duties already paid, subject to the detailed conditions of the rules. Direct application in certain cases requires documents endorsed by the Commander of the Lithuanian Armed Forces or an authorised person. Refund claims require the prescribed application, an endorsed list of goods or services and supporting purchase documents; proof of payment must be supplied if requested.

The resolution also sets out procedures and restrictions for qualifying members of foreign armed forces, accompanying civilian personnel and family members where the underlying arrangements provide for such relief. The scope of any exemption must be assessed against the particular agreement and transaction.

STI updates its commentary on progressive personal income tax rates

On 14 October 2026, the Lithuanian State Tax Inspectorate announced a revised commentary on parts 1, 2 and 6–11 of Article 6 of the Law on Personal Income Tax (PIT). The guidance reflects amendments enacted in 2025 and applicable under the 2026 personal income tax framework.

Under Article 6(1), the general progressive schedule applies a 20% rate to the annual income portion not exceeding 36 national average monthly wages (AW), 25% to the portion above 36 AW but not above 60 AW, and 32% to the portion above 60 AW.

Article 6 also provides special treatment for particular categories. For example, qualifying non-employment income falling within Article 6(2) may be subject to a 15% rate up to the statutory 12 AW limit. Separate 15% treatment applies to dividends and certain other categories, including qualifying disposals of shares held for more than five years and investment account income. Specific rules apply to self-employment and agricultural income, and Article 6(11) establishes the order for including certain income categories when the progressive rate is determined.

Updated guidance on business travel expenses and daily allowance rules

On 23 October 2026, the STI announced an update to its commentary on Article 21(3) of the Law on Corporate Income Tax, concerning the deduction of business travel expenses. The announcement links the update to Government Resolution No. 518 of 1 July 2026, which amended daily allowance and travel reimbursement rules, principally with effect from 1 October 2026.

Under the amended daily allowance rules, a collective agreement may set rates below the statutory maximum, provided they are not less than 50% of the maximum. Where no collective agreement exists, an internal normative or administrative act may set rates of at least 65% of the maximum for business trips lasting at least seven days. Employees must be notified in writing of reduced rates before their trip.

New provisions specify a 20% daily allowance for the first and/or last day of a business trip where that day lasts less than four hours, including travel time to and from the workplace designated by the employer. Other provisions address itineraries covering several countries and domestic trips, for which the amended rules provide daily allowances where the trip lasts longer than one day.

Article 21(3) of the Corporate Income Tax Law refers the deductibility of business travel expenses to the procedures established by the Government or its authorised body. The STI's October announcement confirms that the corresponding tax commentary has been updated.

Lithuanian Supreme Administrative Court refers third-party transport export VAT case to the CJEU

In its 7 October 2026 order in administrative case No. eA-104-789/2026, the Lithuanian Supreme Administrative Court (LVAT) referred two questions to the Court of Justice of the European Union (CJEU) concerning the interpretation of Article 146(1)(b) of the VAT Directive.

The dispute concerns the Lithuanian trader UAB “Ramsiga”, which supplied used clothing and footwear to Absolute Export LP, a company registered in the United Kingdom and holding a Latvian VAT number. Eight invoices covering goods worth EUR 633,534.68 were at issue. Customs export declarations, CMR consignment notes and IE599 confirmations established that the goods had been transported directly from Lithuania to Belarus.

However, the carriers had been contracted and paid by third parties established in Canada and the Seychelles, rather than directly by the contractual buyer. The tax authority considered this incompatible with the requirements for applying a zero VAT rate to the disputed supplies and assessed EUR 133,043 in additional VAT, plus related amounts.

According to the court's order, the physical departure of the goods from the EU was not disputed; neither did the tax authority allege that the Lithuanian supplier had acted dishonestly. The buyer later stated that it had orally instructed the intermediary companies to arrange the transport, but the case file did not contain contemporaneous written documentation of those instructions.

The LVAT asked whether third-party organisation and payment of carriage necessarily excludes the export exemption where the goods indisputably left the EU and the buyer had the right to dispose of them as owner. It also asked whether an honest supplier may subsequently be required to account for VAT if the goods were not dispatched on the buyer's behalf or the buyer no longer had the right to dispose of them when they were exported, without the supplier being aware of those circumstances.

The LVAT stayed the national proceedings pending the CJEU preliminary ruling. The substantive VAT liability in this case has not yet been determined.

Tax Disputes Commission: unpaid loan may become taxable when the lender is liquidated

In Decision No. S-2026/196 (7-2026/139) of 2 September 2026, Lithuania's Tax Disputes Commission (MGK) addressed the personal income tax consequences of an outstanding loan where the creditor had been liquidated. The dispute also included the taxpayer's proceeds from the sale of shares (interests) in an agricultural company.

The individual had received a EUR 318,582 loan in 2012 from a public institution. The institution was liquidated on 12 May 2023 at the initiative of the Register of Legal Entities. The Commission found no evidence that the loan had been repaid or that the creditor's right to repayment had been transferred to another person.

The tax authority treated the expiry of the repayment obligation in 2023 as the moment at which the borrower received an economic benefit. The taxpayer argued that, if the loan was taxable, the income should have been attributed to 2012, placing the assessment outside the relevant limitation period.

The Commission distinguished between receiving a genuine repayable loan, which does not by itself constitute taxable income, and a later event that brings the repayment obligation to an end. Applying Article 6.128(3) of the Lithuanian Civil Code to the circumstances established in the case, it concluded that the borrower received a taxable economic benefit in 2023 when the lender was liquidated without transfer of the repayment claim. The statute-of-limitations objection was therefore rejected.

The Commission also upheld the tax authority's treatment of EUR 108,568.50 in agricultural-company interest sale proceeds and did not accept the evidence submitted to support the taxpayer's claimed acquisition cost. The outcome was EUR 72,067.37 of additional PIT and EUR 15,355.76 of late-payment interest, while the PIT penalty was reduced by 20%, from EUR 40,492.43 to EUR 32,393.95. In reducing the penalty, the Commission referred to the passage of time, difficulties in obtaining historical evidence and the absence of established intentional misconduct.

About this publication. These updates summarise official legislation, legislative drafts, tax authority announcements and published decisions. Proposed legislation is identified as such. A court referral is not a final ruling on the underlying tax dispute. The information is general and does not replace an assessment of individual circumstances.

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