On 4 September 2025, the ECJ ruled on a case involving VAT and transfer pricing adjustments, which could impact intra-group TP corrections. The case involved Arcomet Romania and Arcomet Belgium, where VAT was initially applied to intra-group services but later challenged. The ECJ determined that transfer pricing adjustments can fall within the scope of VAT if there is a legal relationship and direct link between services and consideration.
However, not all transfer pricing adjustments automatically fall under VAT; it depends on the contractual agreements and evidence of service use.
Source: bakertilly.nl
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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