- Transfer pricing (TP) concerns prices charged in transactions between connected parties
- UK transfer pricing legislation based on arm’s length principle
- TP adjustments in UK can only increase taxable profits or reduce tax loss
- TP adjustments usually outside scope of VAT as they are for direct tax purposes
- Price adjustments of previous supply must be recognized for VAT market value rules in certain cases
- Case Arcomet Romania to be heard by CJEU on whether TP adjustments represent consideration
- UK courts can now deviate from ECJ case law after Brexit.
Source: marcusward.co
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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