TP adjustments: what treatment for VAT purposes?

In order to establish whether the financial adjustments made in implementation of the TP adjustments represent the consideration for a transaction relevant for the purposes of value added tax, it is first necessary to verify the existence of a legal relationship with reciprocal benefits between the company. and its foreign subsidiaries and, consequently, to verify whether in the aforementioned relationship there is a direct link between the transfers made by way of TP adjustments and any sale of goods and / or provision of services rendered by the company. This was announced by the Inland Revenue with the response to ruling no. 884 of 30 December 2021.