The trend of recent years, when, in order to optimize taxes, the aim is not to create a structure of a group of companies that crosses the borders of Lithuania, but to “return” companies “held” abroad (holdings, SPVs) and other investments to Lithuania. This trend has become more profound in recent years as tax administrations use more and more tools to combat tax evasion and aggressive tax planning (Organization for Economic Co-operation and Development (OECD) project on combating tax base erosion and profit shifting (BEPS), etc.).
For example in response to the above, in one of the client’s cases, we had to review and evaluate the cross-border structure when the client- a well-known shopping complex – managed a group of companies that were established in such jurisdictions as Liechtenstein, Malta, and so on. Our task was to simplify the structure of groups of companies, eliminate non-Lithuanian companies, and to lay down alternatives on how to do it, with the lowest possible tax burden and minimal risk.