Lithuania: MoF publishes draft Law on implementation of Pillar 2 Global Minimum Tax


On 27 October 2023, the Lithuanian Ministry of Finance (MoF) published a draft law for the partial implementation of the Pillar 2 global minimum tax in accordance with  EU Council Directive 2022/2523 of 14 December 2022. The proposed legislation intends to implement a qualified domestic top-up tax starting in 2025. Given that only five ultimate parent entities of large-scale groups fall within the Directive’s scope and are situated in Lithuania, the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR) will not be enforced until 31 December 2029.

Lithuania also introduced a draft law outlining penalties for non-compliance with the global minimum tax requirements. Managers of legal entities or other responsible individuals face fines ranging from EUR 1,800 to EUR 3,800 for initial offenses. For repeat offenses, the penalty increases to a range of EUR 3,800 to EUR 6,000.



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