Experiences of the Tax Disputes Commission in 2024: trends and changes
The Tax Disputes Commission under the Government of the Republic of Lithuania (the Commission) has published its results for 2024, which reveal an increase in the complexity of disputes and the number of decisions not approved by tax administrators.
According to the Commission's data, 283 decisions were made in 2024. Fifty-four percent of the tax administrator's decisions were approved, while 46 percent of tax dispute cases were returned for reconsideration, and the tax administrator's decision was revoked or amended.
Last year, compared to the previous year, the total amount of tax disputes examined by the Commission increased by one-fifth, amounting to EUR 20.6 million (in 2023 – EUR 15.98 million), i.e. the total amount of decisions adopted by the Commission increased by 22 percent. Last year, of all complaints submitted to the Commission, 62 percent were submitted by legal entities and 38 percent by natural persons.
Of all the complaints submitted to the Commission last year, 62 percent were submitted by legal entities and 38 percent by natural persons. Compared to 2023, when legal entities accounted for 56 percent of complaints, there has been a noticeable increase in the share of business entities in disputes over the past few years. Almost half of the applicants represented their own interests and did not hire lawyers, which testifies to the simplicity and accessibility of the Commission's process.
In 2024, most disputes arose over value added tax (VAT) and personal income tax (PIT). The Commission resolved tax dispute cases concerning the decisions of the following state institutions: the State Tax Inspectorate under the Ministry of Finance of the Republic of Lithuania (74% of cases), the Customs Department under the Ministry of Finance of the Republic of Lithuania (17% of cases), and the Environmental Protection Department under the Ministry of the Environment (9% of cases).
Although most disputes still arise from decisions made by the State Tax Inspectorate, it has been noted that the number of disputes concerning decisions made by the Customs Department has decreased by 5%, while the number of disputes concerning decisions made by the Department of Environmental Protection has increased.
In order to ensure that the decisions taken are well-founded and objective, in 2024 the Commission referred the most cases to the Court of Justice of the European Union (CJEU) during the Commission's term of office, becoming the second institution in Lithuania in terms of the number of requests submitted. The questions submitted to the ECJ related to international artificial arrangements aimed at tax benefits, the determination of the VAT object (game currency) in virtual space, and the coordination of sanctioning and criminal prosecution procedures.
Commission Chair Vilma Vildžiūnaitė emphasized the growing confidence in the Commission's work: "As many as 72 percent of our decisions were not appealed in court, which shows growing confidence in the Commission's objectivity and professionalism. Not appealing the Commission's decisions in court also reduces the workload of the courts. The number of Commission decisions that remain unchanged in court is also important – as many as 80 percent of the decisions appealed remained unchanged."
There is a noticeable trend that tax disputes have become more complex and diverse. The most complex disputes are related to international taxation, chain transactions, or abuse. For example, various business disputes arose when the tax administrator recognized that transactions were concluded to satisfy the interests of shareholders in terms of content supremacy, tax incentives were applied by abusing tax law norms, and transactions were priced inappropriately. Among these was the first ever dispute over the taxation of dividends received from a foreign company with characteristics of an artificial entity at the level of the parent company, applying an EU rule against the abuse of dividend relief.
Commission members also participated in international events in EU countries, such as Estonia and Austria, where they shared their experience with judges from other countries and deepened their knowledge of complex international tax disputes. The Commission also actively contributed to public education by organizing training sessions and participating in conferences and events to raise awareness of tax disputes and promote honest tax payment.
Appealing to the Commission is a simpler, faster, and more economical way to resolve tax disputes. The Commission ensures transparent and impartial decision-making. The decision-making procedure is flexible and adapted to both legal and natural persons. Disputes examined by the Commission allow for legal clarity at an early stage, saving time and reducing the costs that would be incurred in court proceedings.
The attached chart shows data for 2021-2024.
Chart. Final decisions of the Commission
Last updated: 20-11-2025
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