- 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 CJEU 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 CJEU 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"
- Recent ECJ/General Court VAT Jurisprudence and Implications for EU Compliance (Sept 2025)
- Implementing a ViDA Implementation Strategy – What Should You Know?
- ECJ VAT Cases decided in 2025
- ECJ C-535/24 (Svilosa) – Judgment – Acts by a creditor to recover debt without debtor’s mandate aren’t classified as ‘supply of services’
- ViDA Risks: Key Concerns Highlighted by the European Commission