- The Arcomet case involves a Romanian subsidiary and its Belgian parent company in the crane industry.
- The case focuses on transfer pricing adjustments and their impact on VAT.
- The ECJ ruled that transfer pricing adjustments are not neutral for VAT purposes.
- The Romanian subsidiary used management services from the Belgian parent company.
- A profitability arrangement was in place, leading to corrective invoices based on actual margins.
- Traditionally, tax authorities viewed transfer pricing adjustments as not affecting VAT reporting.
- Belgian tax authorities argued for VAT corrective invoices due to transfer pricing adjustments.
- The Advocate General stated that the adjustments should be considered as services subject to VAT.
- The ECJ confirmed the Advocate General’s opinion in its judgment on 4 September 2025.
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.
Latest Posts in "European Union"
- Loyalty Points Are Not Vouchers for VAT: CJEU AG Opinion in Lyko Operations Case
- EU Charter Sets Procedural Safeguards and Limits Sanctions in VAT Enforcement: Key CJEU Rulings
- CJEU Clarifies VAT on Transfer Pricing Adjustments and Intra-Group Services: Key Implications for Businesses
- EU VAT Reforms and Menstrual Poverty: Addressing Access to Affordable Sanitary Products
- Making ViDA Work: Reflections on the ViDA Implementation Dialogue
