Victory against tax authorities regarding dual residency

Our tax team has successfully represented a private investor in a tax dispute regarding dual residency under the Double Tax Treaty between Lithuania and Russia.

Lithuanian tax authorities have argued that the private investor is a tax resident of Lithuania and is liable to pay EUR 800’000 of personal income tax. However, our law firm successfully convinced Lithuanian tax authorities that our client is a tax resident in another country according to a tie-breaker rule, which is provided in the Double Tax Treaty. Only detailed interpretation of the OECD commentaries and wide knowledge of the foreign case-law allowed our law firm to provide a victorious consultation regarding the interpretation of the tie-breaker residency rule which abolished personal income tax calculated to the client.