Comments on ECJ Case C-726/23 (Arcomet) – Transfer Pricing Adjustments Impact VAT in Arcomet Case

• 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.

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