Arcomet Case: CJEU’s New Stance on Transfer Pricing Adjustments and VAT Implications

• The Arcomet case (C-726/23) introduces a new perspective on transfer pricing adjustments and VAT.
• The case involves the Romanian subsidiary Arcomet and its Belgian parent company, focusing on management services and profit level arrangements.
• The Advocate General’s opinion suggests that transfer pricing adjustments may lead to VAT obligations, contrary to previous views.
• The Belgian tax authorities believe that transfer pricing adjustments should result in corrective VAT invoices.
• The CJEU ruling is anticipated on 4 September 2025.
• The Advocate General argues that the adjustments relate to specific services provided by the parent company, impacting VAT.

Source: mddp.pl

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.