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Arcomet Towercranes: CJEU Reference on VAT and Transfer Pricing Adjustments

  • Between 2011 and 2013, Arcomet Towercranes SRL’s profits in Romania exceeded the ceiling set by a transfer pricing study
  • Arcomet Belgium issued an invoice to Arcomet Romania for €695k
  • Arcomet Romania accounted for VAT on the payments under the reverse charge mechanism
  • Romanian tax authorities denied input tax recovery to Arcomet Romania
  • The Romanian court has asked the CJEU whether transfer pricing adjustments represent consideration for a supply of services and how groups should evidence the link between those services and business activities

Source: taxscape.deloitte.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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