Our tax law experts successfully represented a private investor in a tax investigation initiated by Lithuanian tax authorities.
Despite the fact that the private investor was also a resident for tax purposes in another state, Lithuanian tax authorities initiated a tax investigation of the private investor’s source of income. Taking into consideration that the private investor was a resident both in Lithuania and another state, our tax litigation team raised a question of where the private investor was a resident with respect to the tie-breaker rule of dual residence.
By using the OECD commentaries and foreign case-law, our team has successfully convinced the Lithuanian tax authorities that the private investor was not a Lithuanian resident with regard to the double tax treaty between Lithuania and another contracting state. Therefore, the tax investigation of our client was dismissed.