- The EU Court of Justice (ECJ) issued several rulings in 2025 clarifying the relationship between transfer pricing adjustments and VAT.
- In case C-726/23 (Arcomet Towercranes), the ECJ ruled that transfer pricing adjustments reflecting real services between related parties are subject to VAT.
- The court confirmed that such adjustments are not merely financial transactions but can be taxable supplies if they compensate for actual services rendered.
- The decision aligns with the Czech approach to VAT on transfer pricing but leaves some questions open, such as the reverse situation (subsidiary invoicing the parent).
- Another case (C-527/23, Weatherford Atlas Gip) addressed VAT deduction rights for shared group services, with costs allocated among group entities.
Source: accace.cz
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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