Peer Review of the Automatic Exchange of Financial Account Information 2025 Update

Lithuania

Overall findings

Lithuania’s legal framework implementing the AEOI Standard is in place but needs improvement in order to be fully consistent with the requirements of the AEOI Terms of Reference. While Lithuania’s international legal framework to exchange the information with all of Lithuania’s Interested Appropriate Partners (CR2) is consistent with the requirements, its domestic legislative framework requiring Reporting Financial Institutions to conduct the due diligence and reporting procedures (CR1) has deficiencies significant to the proper functioning of elements of the AEOI Standard. More specifically, deficiencies have been identified in relation to Lithuania’s enforcement framework.

The methodology used for the peer reviews and that therefore underpins this report is outlined in Annex A.

Overall determination on the legal framework: In Place But Needs Improvement

Conclusions on the legal framework

General context

Lithuania commenced exchanges under the AEOI Standard in 2017.

In order to provide for Reporting Financial Institutions to collect and report the information to be exchanged, Lithuania:

• enacted Article 61-¹ of the Law on Tax Administration, Resolution No. 1017 of 23 September 2015, and amended Article 48 of that Law in 2025;

• introduced the Rules for the Provision of Information Necessary for Implementation of the International Cooperation Obligations Concerning Automatic Exchange of Financial Account Information (amended in 2024);

• introduced Article 198^_1 of the Code of Administrative Offences of 3 December 2019; and

• issued further guidance, which is legally binding.

Under this framework Reporting Financial Institutions were required to commence the due diligence procedures in relation to New Accounts from 1 January 2016. With respect to Preexisting Accounts, Reporting Financial Institutions were required to complete the due diligence procedures on High Value Individual Accounts by 31 December 2016 and on Lower Value Individual Accounts and Entity Accounts by 31 December 2017.

Following the initial Global Forum peer review, Lithuania amended its legislative framework to address issues identified, most recently with effect from 1 January 2026.

With respect to the exchange of information under the AEOI Standard, Lithuania:

• is a Party to the Convention on Mutual Administrative Assistance in Tax Matters and activated the associated CRS Multilateral Competent Authority Agreement in time for exchanges in 2017;

• has in place the European Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation as amended by Directive 2014/107/EU;

• has in place European Union agreements with five European third countries;1 and

• put in place a bilateral agreement.2

Detailed findings

The detailed findings for Lithuania are below, organised per Core Requirement (CR) and sub-requirement (SR), as extracted from the AEOI Terms of Reference (see Annex B).

CR1 Domestic legal framework: Jurisdictions should have a domestic legislative framework in place that requires all Reporting Financial Institutions to conduct the due diligence and reporting procedures in the CRS, and that provides for the effective implementation of the CRS as set out therein.

Determination: In Place But Needs Improvement

Lithuania’s domestic legislative framework is in place and contains most of the key aspects of the CRS and its Commentary requiring Reporting Financial Institutions to conduct the due diligence and reporting procedures, but it needs improvement in relation to the framework to enforce the requirements (SR 1.4). More specifically, Lithuania does not provide for sanctions on Reporting Financial Institutions for failing to carry out the due diligence procedures or failing to keep records in all cases.

SR 1.1 Jurisdictions should define the scope of Reporting Financial Institutions consistently with the CRS.

Lithuania has defined the scope of Reporting Financial Institutions in its domestic legislative framework in accordance with the CRS and its Commentary.

Recommendations:

No recommendations made.

SR 1.2 Jurisdictions should define the scope of Financial Accounts and Reportable Accounts consistently with the CRS and incorporate the due diligence procedures to identify them.

Lithuania has defined the scope of the Financial Accounts that are required to be reported in its domestic legislative framework and incorporated the due diligence procedures that must be applied to identify them in accordance with the CRS and its Commentary.

Recommendations:

No recommendations made.

SR 1.3 Jurisdictions should incorporate the reporting requirements contained in Section I of the CRS into their domestic legislative framework.

Lithuania has incorporated the reporting requirements in its domestic legislative framework in accordance with the CRS and its Commentary.

Recommendations:

No recommendations made.

SR 1.4 Jurisdictions should have a legislative framework in place that allows for the enforcement of the requirements of the CRS in practice.

Lithuania has a legislative framework in place to enforce the requirements in a manner that is largely consistent with the CRS and its Commentary. However, a deficiency has been identified. More specifically, Lithuania’s legislative framework does not impose sanctions for failing to carry out the due diligence procedures or failing to keep records required under the AEOI Standard where it does not impact reporting. These are key elements of the required enforcement framework and are therefore material to the proper functioning of the AEOI Standard.

Recommendations:

While Lithuania is able to impose penalties for failing to report and for reporting incorrect information, it is recommended to amend its legislative framework to ensure it is able to also impose penalties for failing to carry out due diligence and failing to keep records.

CR2 International legal framework: Jurisdictions should have exchange relationships in effect with all Interested Appropriate Partners as committed to and that provide for the exchange of information in accordance with the Model CAA.

Determination: In Place

Lithuania’s international legal framework to exchange the information is in place, is consistent with the Model CAA and its Commentary and provides for exchange with all of Lithuania’s Interested Appropriate Partners (i.e. all jurisdictions that are interested in receiving information from Lithuania and that meet the required standard in relation to confidentiality and data safeguards). (SRs 2.1 – 2.3)

SR 2.1 Jurisdictions should have exchange agreements in effect with all Interested Appropriate Partners that permit the automatic exchange of CRS information.

Lithuania has exchange agreements that permit the automatic exchange of CRS information in effect with all its Interested Appropriate Partners.

Recommendations:

No recommendations made.

SR 2.2 Such an exchange agreement should be put in place without undue delay, following the receipt of an expression of interest from an Interested Appropriate Partner.

Lithuania put in place its exchange agreements without undue delay.

Recommendations:

No recommendations made.

SR 2.3 Jurisdictions should ensure that the exchange agreements in effect provide for the exchange of information in accordance with the requirements of the Model CAA.

Lithuania’s exchange agreements provide for the exchange of information in accordance with the requirements of the Model CAA.

Recommendations:

No recommendations made.

Comments by the assessed jurisdiction

On 11 September 2025, the Parliament of the Republic of Lithuania adopted an amendment to Article 207 of the Code of Administrative Offences (No. XV-415). This amendment will enter into force on 1 January 2026 and addresses the recommendations outlined in this report.

Notes

Notes

← 1.  Andorra, Liechtenstein, Monaco, San Marino and Switzerland.

← 2.  With Singapore.