Experiences of the Tax Disputes Commission in 2025
The Tax Disputes Commission under the Government of the Republic of Lithuania (the Commission) has published its 2025 performance results, which reveal a growing number of decisions not approved by tax administrators, the expansion of international cooperation, and the opportunity to more easily defend rights in the digital space.
In 2025, the Commission issued 228 decisions. Of all decisions issued, in 58% of cases, the tax administrator’s decisions were overturned, amended, or remanded for reconsideration, i.e., the applicants’ appeals were fully or partially upheld. Of the decisions not upheld, 11% were annulled, 49% were partially annulled (amended), and 40% were remanded. In 2025, compared to 2024, the proportion of tax administration decisions that were amended increased by approximately 26%.
Last year, the majority of disputes arose regarding value-added tax (VAT), personal income tax (PIT), and customs duties. The most common topics of tax disputes relate to the assessment of the reality of transactions, the application of potential tax avoidance schemes, the recognition of VAT deductions, the application of customs procedures, and issues regarding the recognition of expenses.
Most often, tax authorities’ decisions are overturned due to insufficient assessment of the facts, the submission of new evidence, the application of tax law principles, and insufficient reasoning in the decisions.
The total amount of tax disputes examined by the Commission amounted to 17.8 million euros. The disputed amount regarding personal income tax (PIT) increased the most, more than doubling: it rose from 3.45 million euros in 2024 to 8 million euros.
In 2025, the activity of natural persons increased—they filed 43% of all complaints, while legal entities filed 57%. In 2024, complaints from individuals accounted for 38%. A significant portion of applicants defend their rights independently, without hiring lawyers or tax specialists.
Commission Chairwoman Vilma Vildžiūnaitė highlights the consistency of the Commission’s decisions: “The consistency of decisions is the best indicator of the quality of the Commission’s work—last year, approximately 80 percent of the Commission’s decisions that were appealed in court remained unchanged. The factual circumstances clarified by the Commission and the conclusions of the professional tax analyses presented contribute to the interpretation of tax law provisions and the formation of application practices, which are taken into account not only by administrative court judges but also by taxpayers and tax administrators in their activities.”
The Commission examined disputes regarding decisions made by three state institutions. The majority, 64 percent, consisted of disputes regarding decisions by the State Tax Inspectorate, although this figure decreased compared to 2024 (74 percent). Disputes regarding decisions by the Customs Department increased—their share rose from 17% in 2024 to 27% in 2025. The share of the Department of Environmental Protection remained stable at 9%.
In 2025, in order to properly examine the complaint, the Commission actively cooperated with the Court of Justice of the European Union (CJEU), which has recognized the Commission as a judicial body. The Commission referred a matter to the CJEU for a preliminary ruling. In addition, last year Commission staff visited the CJEU, where seminars and meetings were held with CJEU judges, the Advocate General, and other staff.
In expanding its international relations, the Commission also established international ties for the first time with a counterpart institution abroad—the Irish Tax Disputes Commission—with which it shared best practices in dispute resolution and the implementation of operational changes.
In 2025, the dispute resolution process was further improved. In collaboration with the State Tax Inspectorate, the complaint submission form was simplified, and the option to submit complaints directly via the information system was introduced. Proposals for legislative amendments were drafted to standardize and expand the practice of pre-trial dispute resolution so that it covers all tax-related disputes.
The Commission also pays special attention to maintaining employee professionalism and improving qualifications—in 2025, there was an increase in training sessions where employees improved both their professional knowledge and general skills.
The Tax Disputes Commission is a swift, independent pre-trial body that issues decisions no later than 60 days after receiving a complaint. Last year, the average decision-making period was 50 days. The Commission ensures the protection of taxpayers’ rights and provides an opportunity to objectively defend one’s rights against the tax administrator.
Last updated: 18-05-2026
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