- 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
- VAT treatment of TP adjustments not covered in UK legislation or case law
- TP adjustments may affect VAT market value rules in certain circumstances
- 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: deeksvat.co.uk
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.
