The State Tax Inspectorate of Lithuania published an updated commentary on 13 October 2025 regarding Article 61-2 of the Law on Tax Administration, which implements the EU Amending Directive 2018/822 (DAC6), requiring reporting of certain cross-border arrangements that could be used for aggressive tax planning.
The commentary provides clearer guidance on the mandatory disclosure obligations for cross-border arrangements. The commentary specifies who qualifies as an “intermediary,” including professionals such as tax consultants and lawyers, and outlines the circumstances under which they must report arrangements connected to Lithuania.
Reporting must be made within 30 days of preparation or implementation of the arrangement.
In cases where an intermediary is absent or claims professional secrecy, the reporting responsibility shifts to the “interested taxpayer.”
The guidance also clarifies how to determine which country’s tax authority should receive the report when multiple jurisdictions are involved.
