Corporate Tax 2008

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A practical insight to cross-border Corporate Tax work

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The International Comparative Legal Guide to:

ACCURA AdvokataktieselskabArnold Bloch LeiblerArthur CoxAvanzia Tax AdvisorsBarros & Errázuriz AbogadosBC Toms & Co.BMR & AssociatesBredin PratBugge, Arentz-Hansen & RasmussenBustamante & Bustamante Camozzi Bonissoni Varrenti & AssociatiCárdenas & CárdenasCastrén & Snellman Attorneys Ltd.Delchev & PartnersDespacho de Abogados miembros deMacleod Dixon, S.C.Dorda Brugger Jordis

Elvinger, Hoss & Prussen EubeliusG. BREUERGencs Valters Law FirmGide Loyrette NouelGoodrich, Riquelme y AsociadosHendersen TaxandHerzog, Fox & NeemanJuridicon Law FirmKilpatrick StocktonKim & ChangKyriakides Georgopoulos & Daniolos IssaiasLaw FirmLaw Office Aivar PilvLaw Office Jadek & PensaLenz & StaehelinLinklaters LLPLOGOS Legal ServicesLovells LLP

Machado, Meyer, Sendacz e Opice AdvogadosMacleod DixonMichael Kyprianou & Co.Nagashima Ohno & TsunematsuPachiu & AssociatesP+P Pöllath + PartnersPaul, Weiss, Rifkind, Wharton & Garrison LLPPepeliaev, Goltsblat and PartnersPrijohandojo, Boentoro & Co.Salans LLPSalans D. Oleszczuk Kancelaria Prawnicza Sp. k.Slaughter and May Van Doorne N.V.Werksmans Inc.White & Case WongPartnershipZaid Ibrahim & Co

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Chapter 31

Juridicon Law Firm

Lithuania

1 General: Treaties

1.1 How many income tax treaties are currently in force inyour jurisdiction?

Lithuania currently has forty-five treaties on the avoidance ofdouble taxation of income and capital in force.

1.2 Do they generally follow the OECD or another model?

The treaties follow the Lithuanian Model Tax Treaty that is basedboth on OECD and United Nations Model Tax Conventions, takinginto consideration the remarks of OECD experts.

1.3 Do treaties have to be incorporated into domestic lawbefore they take effect?

These treaties are applied directly and do not have to beincorporated into domestic laws. The treaties come into force afterthey have been signed and ratified by the Lithuanian Parliament.The treaties themselves may also indicate a later moment of cominginto force.

1.4 Do they generally incorporate anti-treaty shopping rules (or“limitation of benefits” articles)?

Lithuanian treaties on avoidance of double taxation usually do notincorporate special anti-treaty shopping rules, with minorexceptions (e.g. the treaties with the USA, UK, etc.). Nevertheless,most of them contain beneficial ownership requirements in thearticles regulating taxation of dividends, interest and royalties andan arm's length requirement applicable to the transactions betweenrelated parties.

1.5 Are treaties overridden by any rules of domestic law(whether existing when the treaty takes effect orintroduced subsequently)?

International treaties have supremacy over domestic laws inLithuania. As the treaty comes into force, it overrides the domesticlaws of the same field, unless it is stated otherwise in the treatyitself or if the national law provides a more favourable regime.

2 Transaction Taxes

2.1 Are there any documentary taxes in your jurisdiction?

Stamp duties and State fees of exactly established amounts areapplied only for the precisely defined formal services of Stateinstitutions, e.g. review of the application, issue of the document.

2.2 Do you have Value Added Tax (or a similar tax)? If so, atwhat rate or rates?

Lithuania has value added tax which is harmonised with the EUacquis. The standard VAT rate equals 18%. The reduced 9% rate of VAT is applied on supplies of services relatingto the construction, renovation and insulation of residential houses,financed with special State and municipal resources or credits.The reduced 5% rate of VAT is applied to certain services andgoods, such as passenger transportation by regular routes, mostbooks, newspapers and periodicals, pharmaceuticals,accommodation services, organic food products, certain kinds ofmeat and fish, some kinds of art, cultural and sporting events,creative and performance services, provided by a writer, composeror performer.0% rate VAT is charged mainly on goods exported from the EU andcertain related services as transportation and insurance, as well ason certain supply of goods to another EU Member State, and alsoon a few other occasions prescribed by law.

2.3 Is VAT (or any similar tax) charged on all transactions orare there any relevant exclusions?

In general, VAT is charged on every supply of goods or services,when the supply is effected by a taxable person in the performanceof his economic activities, if the supply is for consideration andeffected within the territory of Lithuania. Still, certain supplies ofgoods and services (such as healthcare, social, education, cultureand sport nature; certain mail services, radio, television, insurance,financial services, rent or sale of some real property, betting,gambling and lottery services, special marks), as well as someintra-community acquisitions, stay exempt from VAT.

2.4 Is it always fully recoverable by all businesses? If not,what are the relevant restrictions?

Under the Law on VAT of the Republic of Lithuania (the Law on

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VAT), input/import VAT may be entered for deduction if the goodsor services purchased are used for the taxable supply. With someexceptions, input/import VAT that is directly or proportionallyattributed to the supply exempted from VAT cannot accordingly (ina whole or proportionally) be deducted. Under the Law on VAT, insome cases input/import VAT on the acquisition of entertainmentand representation goods and services, motor vehicles, passengertransport services and also VAT paid on behalf of another personcannot be deducted, or its deduction is limited.VAT paid in Lithuania is recoverable; still, a few circumstancesexist which should be noted. According to the laws, the differencebetween input and output VAT will firstly be included to cover thetax arrears of the same taxpayer, the overdue state loans to thetaxpayer or the overdue loans, warranted by the state. Theremaining part of excess of VAT may be returned only to thetaxpayer which has paid into the budget and funds all the taxes,default interest, penalties and interest for overdue tax; whichsubmitted all the requisite tax returns or accounts; and which wasnot penalised for the malignant breach of tax laws, or if more thanthree years has passed since such a breach. Moreover, the VAT willbe refunded only if there are no open tax disputes in respect of therequested refund. The Law restricts the maximum recoverable VAT sum to the sum ofconditional or calculated VAT on taxable amounts of particularcategories goods and services prescribed by the Law on VAT, suchas goods and services in respect of which the 0% VAT rate wasapplied, acquired capital assets, etc.As regards a foreign person's right to recover VAT, under the Lawon VAT, a taxable foreign person that (i) is established in anotherEU Member State; (ii) is established in a third country andregistered as a VAT-payer in an EU Member State for the electronicsupply of services; or (iii) is established in a third country where theVAT paid (or any equivalent tax) is refundable to taxable persons ofLithuania, has a right to recover the VAT paid in Lithuania. Withsome exceptions, the foreign taxable person may apply for recoveryof VAT only when he had no subdivision or place of residence anddid not engage in commercial activity in Lithuania during theperiod in which he paid the VAT which he is asking to be refunded.

2.5 Are there any other transaction taxes?

No, there are no other transaction taxes.

2.6 Are there any other indirect taxes of which we should beaware?

According to the EU Customs Code and related legal acts, customduties on particular goods imported into the EU within the territoryof Lithuania are levied.Excise duties are charged on ethyl alcohol and alcoholic beverages,manufactured tobacco, energy products (fuel, oil, gas, blackdiamond, etc.) and electricity.Environment pollution tax is levied on subjects that in the course oftheir economic activity emit pollution, or manufacture or importinto the Lithuanian market goods and/or packing that are potentialsources of pollution (tyres, accumulators, batteries, oil and airfilters, oil buffers, glass, plastic, metallic and other packing).Taxpayers that implement anti-pollution or treatment of wastestandards may be exempted from corresponding taxation.

3 Cross-border Payments

3.1 Would there be any WHT on royalties paid by a localcompany to a non-resident?

In general, under the Law of the Republic of Lithuania on CorporateIncome Tax (the Law on Corporate Income Tax), all the royalties(for use or transfer of copyright and related rights, includingsoftware, rights to use industrial ownership - patents, trademarks,models, know-how) paid by a Lithuanian company to a non-resident company having no permanent establishment in Lithuaniaare subject to 10% withholding tax (without any deductions). The Lithuanian company, while paying a royalty to a foreign naturalperson that is not engaging in any related commercial activity inLithuania, must deduct 15% tax on income. However, the applicability of the Lithuanian tax rate on royaltiesmay be mitigated by the Lithuanian treaties on the avoidance ofdouble taxation in force.

3.2 Would there be any WHT on interest paid by a localcompany to a non-resident?

In general, interest paid by a Lithuanian company to non-residents(both natural and legal persons) is taxable at the same order andrates as indicated in question 3.1. However, the following interestis tax-exempt:

interest paid to a legal person on securities issued by theGovernment on international financial markets; interestaccrued and paid on deposits; and interest on subordinatedloans which meet the criteria set down by the legal acts of theBank of Lithuania;with minor exceptions - interest received by a natural personon the loans granted, if the repayment of the loanscommences not earlier than 366 days after the date of thegranting of the loan; and interest received by the naturalperson on securities, if the redemption of those securitiescommences not earlier than 366 days after the date of theissue of those securities; andinterest paid on securities of the Governments and politicalor geographic administrative subdivisions of the memberstates of European Economic Area; as well as interest ondeposits held in banking and other credit institutions,established in the member states of European EconomicArea.

3.3 Would relief for interest so paid be restricted by referenceto “thin capitalisation” rules?

Firstly, Lithuanian thin capitalisation rules apply only to the extent,to which the ratio between the capital borrowed from thecontrolling creditor and the own equity of the entity-debtor exceeds4:1. The interest for the part of the loan exceeding the above-mentioned ratio cannot be deducted from the taxable income of theentity-debtor, unless the debtor proves the presence of the arm'slength principle in respect of the amount and interest of theborrowed capital.For the purposes of the application of thin capitalisation rules, thecontrolling creditor shall be held to be any Lithuanian or foreignlegal or natural person directly or indirectly (i) possessing morethan 50% of the debtor's capital; or (ii) possessing at least 10% ofthe debtor's capital and at the same time together with relatedpersons possessing more than 50% of the debtor's capital. Anymember of a group of entities (a group consisting of a parent entity

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and one or more taxable subsidiaries, in each of which the parententity holds more than 25% capital) as well as the creditor's spouse,fiancé, and relatives up to first grade, shall also be held to becontrolling creditors.While applying thin capitalisation rules, the borrowed capital coversloans granted and convertible bonds issued by the controllingcreditor, loans granted by third persons but guaranteed by thecontrolling creditor, and even loans guaranteed by third persons towhom at the same time the controlling creditor issued the guarantee.The above-mentioned rules are not applicable against the financialinstitutions providing financial rent or financial leasing services.Secondly, the interest or rent fee that depends on debtor's turnover,income, profit and so on, and interest that may be converted into thecreditor's right to the debtor's capital, cannot be deducted from thetaxable income of the debtor. As regards interest paid by a Lithuanian entity or permanentestablishment to foreign entities registered or otherwise organisedin target (“tax haven”) territories, see also question 4.3.

3.4 If so, is there a “safe harbour” by reference to which taxrelief is assured?

As indicated in question 3.3, thin capitalisation rules shall not beapplied to the borrowed capital if the debt and equity ratio of 4:1 isnot exceeded; and even when exceeded, if the arm's length principlein respect to the amount and interest of the borrowed capital isfollowed.

3.5 Would any such “thin capitalisation” rules extend to debtadvanced by a third party but guaranteed by a parentcompany?

See question 3.3.

3.6 Is any withholding tax imposed on dividends paid by alocally resident company to a non-resident?

Dividends paid by the Lithuanian entity to the non-resident entityare subject to 15% withholding tax on corporate income. Dividends paid by the Lithuanian entity (the taxable profits ofwhich are taxed at a rate of 15 or 13% or which is situated in a freeeconomic zone) to a foreign entity, that incessantly for at least 12months controls more than 10% of voting shares/member shares inthe Lithuanian entity, shall not be subject to taxation, except forcases where the foreign entity receiving the dividends is registeredor otherwise organised in target (“tax haven”) territories. Thisprovision shall also be applicable when the treaty on avoidance ofdouble taxation provides a less favourable regime.Dividends paid to the non-resident natural person are taxable at therate of 15%.

3.7 Does your country have transfer pricing rules?

Where the conditions created or prescribed by mutual transactionsor economic operations between associated persons (both residentand non-resident) are different from the similar ones created orprescribed between non-associated persons, the tax administratormay re-evaluate the transactions according to their market value insimilar conditions; reassess the taxable income and consequentlythe payable tax on income; and impose fines and penalties for thedelayed payments, if any.

4 Tax on Business Operations: General

4.1 What is the headline rate of tax on corporate profits?

Profits of Lithuanian entities and permanent establishments offoreign entities in general are taxed at the 15% rate. With someexceptions, profits sourced in Lithuania and received by foreignentities otherwise than through their permanent establishmentssituated in Lithuania are levied by the 10% tax on corporate profits. Profits of small entities satisfying the requirements prescribed bylaw are taxable by 13% or by composite 0% and 15% tax oncorporate profits.

4.2 When is that tax generally payable?

The taxation period is usually the calendar year or another twelve-month period requested by the entity. If the income during theprevious year exceeds LTL 100,000.00, the tax on corporate profitfor the next year must be payable in advance in quarterlyinstalments, the first three of which must be paid before the end ofcurrent quarter, and the fourth instalment before the 25th day of thelast month of the quarter. The newly-incorporated entities are released from the obligation topay tax on corporate profit in advance for the first year afterincorporation. The annual declaration must be submitted and the tax mustcompletely be paid (if it does not need to be paid in quarterlyadvance payments) before the first day of the tenth month of thenext tax year.

4.3 What is the tax base for that tax (profits pursuant tocommercial accounts subject to adjustments; other taxbase)?

The tax base of a Lithuanian entity is all income earned in Lithuaniaand foreign countries, and, according to the provision of the Law onCorporate Income Tax, the positive income of its controlled foreignentity or part of such income, as well as the income or a part of suchincome of the relevant European Economic Interest Grouping.The tax base of a foreign entity covers (i) income received fromactivities carried on through a permanent establishment situated inLithuania as well as income earned in foreign countries andattributed to the said permanent establishment if such incomerelates to the activities of a foreign entity in Lithuania; and (ii)determined by law, income sourced in Lithuania and receivedotherwise than through a permanent establishment in Lithuania(most kinds of interest, distributed profits, royalties, payments foruse of related rights, industrial property, know-how, franchise,compensations for violation of copyright and related rights, incomefrom transfer or lease of immovable property in Lithuania).Sponsorship received that was used for purposes other thanspecified in the Law of the Republic of Lithuania on Charity andSponsorship, as well as sponsorship received in cash from a singleprovider during the tax period, exceeding the amount of 250minimum living standards (currently LTL 32,500.00) will alsoconstitute the tax base both of national or foreign entities.When calculating the taxable profits of a Lithuanian entity, non-taxable income, allowable deductions and deductions of limitedamounts shall be deducted from income. The taxable income ofpermanent establishments shall be calculated by deducting from theincome earned the non-taxable income, deductions of limitedamounts and deductions relating to the income earned by a foreign

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entity through a permanent establishment. The taxable profits,earned by a foreign entity otherwise than through a permanentestablishment, shall include all of its income sourced in Lithuaniawithout any deductions.Sums for deduction must be supported by legally valid documentscontaining all the mandatory requisites of accounting documents orif executed by the foreign persons - such documents must allow theidentification of the content of the economic operation. In addition, payments made by a Lithuanian entity or permanentestablishment to foreign entities registered or otherwise organisedin target (“tax haven”) territories shall be treated as non-allowabledeductions, unless the Lithuanian entity or permanent establishmentsupplies evidence to the tax administrator that such payments arerelated to the usual activities of both parties, that the receivingforeign entity controls the assets needed to perform such usualactivities, and that there exists a link between the payments and theeconomically grounded operation.As financial accountability of Lithuanian entities must beconducted following the Business Accounting Standards, approvedby the Institute of Accounting of the Republic of Lithuania, or theInternational Accounting Standards as defined in Regulation (EC)No 1606/2002 of the European Parliament and of the Council of 19July 2002 on the application of international accounting standards,and the taxable income of the entities must be calculated accordingto the Law on Corporate Income Tax, and as the provisions of theselegal Acts differ in various aspects (e.g. different principles for theestablishment of property acquisition price, etc.), the profitcalculated for financial accountability purposes may differ from theone calculated for the corporate income tax purposes.

4.4 If it otherwise differs from the profit shown in commercialaccounts, what are the main other differences?

See question 4.3.

4.5 Are there any tax grouping rules? Do these allow for reliefin your jurisdiction for losses of overseas subsidiaries?

In general, each Lithuanian entity or permanent establishment of aforeign entity in Lithuania is treated as a separate taxpayer.However, income and losses of foreign permanent establishmentsof Lithuanian entity must be included while calculating taxablecorporate income of the Lithuanian entity. Depending on thetreaties on the avoidance of double taxation, the income earnedthrough the permanent establishments abroad and taxed there maybe either released from the Lithuanian tax on corporate income, orthere may be a possibility to deduct proportionally the tax paidabroad from the one payable in Lithuania.Lithuanian tax laws do not allow cross-border use of income orlosses within the group of separate legal entities.Secondly, as indicated in question 4.3, the positive income of thecontrolled foreign entity shall, proportionally to its shares which areowned by the Lithuanian entity, be included in the taxable profits ofthe Lithuanian entity if:

on the last day of the tax period, the Lithuanian entity holdsdirectly or indirectly over 50% of the shares (interests,member shares) or other rights/pre-emptive rights to a part ofdistributable profits in the controlled entity; or on the last day of the tax period the controlling person,together with related persons, holds over 50% of the shares(interests, member shares) or other rights/pre-emptive rightsto a part of distributable profits in the controlled entity, andat the same time holds himself at least 10% of the shares

(interests, member shares) or other rights to distributableprofits or pre-emptive rights to the acquisition thereof; andthe controlled foreign entity (i) is organised in a countrywhich is listed in the special list (“white list”) approved bythe Ministry of Finance of Lithuania, but acquires specialtax exemptions according to the laws of the country ofregistration (e.g., the holding company registered in theGrand Duchy of Luxembourg, the Trieste Free ZoneFinancial and Insurance Centre in Italy, Limited LiabilityCompany in the USA, etc.), (ii) is not registered orotherwise organised both in the “white list” and in the“black list” (“tax haven”) countries but is the payer ofcorporate income tax which amounts to less than 75% ofthe Lithuanian one, or (iii) is registered or otherwiseorganised in target (“tax haven”) territory.

The above-indicated rule shall not be applicable in cases where theincome of a controlled foreign entity comprises only thosepayments made by the controlled entity which are treated as non-allowable deductions, or when the income of a controlled foreignentity comprises less than 5% of the income of the controllingentity.Thirdly, the income of a European Economic Interest Groupingshall, according to the requirements of the laws and in theproportions laid down in the memorandum of association of thegrouping (in the absence of any such provision - in equal shares),also constitute part of the Lithuanian entity's taxable profits.

4.6 Is tax imposed at a different rate upon distributed, asopposed to retained, profits?

No, both distributed and retained profits are taxed at the same rate.

4.7 What other national taxes (excluding those dealt with in“Transaction Taxes”, above) are there - e.g. property taxes,etc.?

Temporary social tax is levied on the taxable profit of entities,calculated according to the Law on Corporate Income Tax. The rateof this tax for 2007 is 3%; and from 2008 this tax should have beenabolished.Tax on immovable property is levied on immovable property ownedby legal persons; and on immovable property owned by the naturalpersons with a commercial purpose or other purpose, but used foreconomic activities. The tax amounts to 0.3-1% (depending on thedecision of the municipality where the property is located) of thetaxing value of the property per year. Private land (excluding public road and forest land, land owned bydiplomatic or consular representatives) owners are charged 1.5%tax on the land per year, calculated from the cost of the land.According to the Law of the Republic of Lithuania on Lottery andGaming Tax, persons operating lotteries and gaming must paylottery and gaming tax of the following amounts: 5% of the totalface value of the tickets distributed in a lottery; in respect of bingo,totalisator and betting - 15% of the total amount of income afterdeduction of the amount of prizes actually paid out; and in the caseof machine gaming and table games, a fixed amount for eachgaming device per quarter, amounting to LTL 600.00-12,000.00.

4.8 Are there any local taxes not dealt with in answers toother questions?

In addition to the above-mentioned taxes, Lithuanian law prescribesState natural resources tax, petroleum and gas resources tax,

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overstock and production tax in the sector of sugar production, taxon additional quota for white sugar production, temporary tax forrestructuring the sugar industry, deductions from income under theLaw of the Republic of Lithuania on Forestry, inheritance tax,contributions to the Guarantee Fund, State social insurancecontributions, compulsory health insurance contributions, fees forthe registration of industrial property objects, stamp duties, State-imposed fees and charges, and consular fees.

5 Capital Gains

5.1 Is there a special set of rules for taxing capital gains andlosses?

Capital gains constitute a part of the taxable income of a taxableperson and are taxed at the ordinary tax rate. Expenses incurred forthe acquisition of the property transferred are in general deductible.The Law on Corporate Income Tax establishes special rules for therecognition and taxation of income from the increase in the value ofassets in certain cases where entities are reorganised, liquidated ortransferred, where a European company or a European cooperativesociety with a registered office in Lithuania transfers its registeredoffice to another EU Member State.

5.2 If so, is the rate of tax imposed upon capital gainsdifferent from the rate imposed upon business profits?

See question 5.1.

5.3 Is there a participation exemption or relief forreinvestment?

For participation exemption regarding corporate income tax onreceived dividends, see question 3.6. There is no relief forreinvestment in Lithuania.

6 Branch or Subsidiary?

6.1 What taxes (e.g. capital duty) would be imposed upon theformation of a subsidiary?

No taxes are imposed, except for State and notary fees.

6.2 Are there any other significant taxes or fees that would beincurred by a locally formed subsidiary but not by abranch of a non-resident company?

No, there are no other such significant taxes.

6.3 How would the taxable profits of a local branch bedetermined?

The taxable profits of a local branch cover all the incomeattributable to the activities of the branch and sourced both inLithuania and in foreign countries, after allowable deduction of theexpenses incurred for the purposes of the branch.

6.4 Would such a branch be subject to a branch profits tax (orother tax limited to branches of non-resident companies)?

Income earned by the foreign company through the branchregistered in Lithuania shall be subject to Lithuanian corporateincome tax at the standard rate of 15%.

6.5 Would a branch benefit from tax treaty provisions, or someof them?

No, usually a branch would not benefit from tax treaty provisions.

6.6 Would any withholding tax or other tax be imposed as theresult of a remittance of profits by the branch?

Remittance of profits by the branch is not subject to anywithholding or other tax (except bank fees).

7 Anti-avoidance

7.1 How does your jurisdiction address the issue of preventingtax avoidance? For example, is there a general anti-avoidance rule or a disclosure rule imposing a requirementto disclose avoidance schemes in advance of thecompany's tax return being submitted?

Starting from 2002 the issue of preventing tax avoidance is resolvedby a combination of general and specific anti-avoidance rulesestablished in Lithuanian tax laws. The main principle and general rule established in the Law on TaxAdministration indicates that in respect of taxes, the content of theactivities carried on by the participants of legal relations shall takeprecedence over their form. It means that where a taxpayer'stransaction, economic operation or any combination is concludedwith a view to gaining a tax benefit (i.e. to defer the deadline for thepayment of tax, to reduce or fully avoid the payable amount of tax,to increase the tax overpayment/difference to be refunded/creditedor to shorten the time limit for refunding the taxoverpayment/difference) the tax administrator shall apply thecontent-over-form principle for the purpose of calculating the tax.In this case the tax administrator shall not take into account theformal expression of the taxpayer's activity and shall recreate thedistorted or hidden circumstances associated with taxation asprovided for in tax laws and calculate the tax pursuant to therelevant provisions of the said tax laws.Complementing the above said principle particular tax lawsestablish the specific anti-avoidance rules, such as the right of thetax administrator to re-evaluate the transactions between associatedpersons (see question 3.7), “thin capitalisation” rule relating to theinterest paid to controlling persons (see question 3.3), treatingpayments made to foreign entities in target (“tax haven”) territoriesas non-allowable deductions (see question 4.3), not allowing thecross-border use of income or losses (see question 4.5), obligationto include into the taxable profits the positive income of thecontrolled foreign entity (see questions 4.3 and 4.5), not allowing todecrease the taxable profits by losses of financial activities, etc.

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Laimonas Marcinkevicius

Juridicon Law FirmTotoriu St. 5-7 LT01121 Vilnius Lithuania

Tel: +370 5 269 11 01Fax: +370 5 269 10 10Email: laimonas@juridicon.ltURL: www.juridicon.lt

Laimonas Marcinkevicius is a partner at Juridicon Law Firm,Attorney at Law. Laimonas Marcinkevicius graduated from theFaculty of Law of Vilnius University in 1998, where he obtainedprofessional qualifications of a qualified lawyer. Laimonas is LL.D.candidate since 2005 and is a lecturer in Mykolo RomerioUniversity, Faculty of Law, and a Member of International BarAssociation, American Bar Association (associate) since 2005.Laimonas Marcinkevicius established his own law firm in 1996; hehas been an attorney at law since 2003. His main practice areas include: joint ventures; foreign investment;mergers and acquisitions; real estate projects and international taxation. Mr Marcinkevicius' working languages are English, Russian andLithuanian.

Ingrida Steponaviciene

Juridicon Law FirmTotoriu St. 5-7 LT01121 Vilnius Lithuania

Tel: +370 5 269 11 00Fax: +370 5 269 10 10Email: ingrida@juridicon.comURL: www.juridicon.lt

Ingrida Steponaviciene is an associate lawyer of Juridicon Law Firm.Mrs Steponaviciene has gained her Master's of Law degree in VilniusUniversity in 2002. She has been a lawyer in Juridicon since 2001,and was recognised as Attorney at Law in 2007. Her practice includes: foreign investment, mergers and acquisitions,competition, tax and labour law.Mrs Steponaviciene's working languages are English, Russian andLithuanian.

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