Comments on ECJ case C-603/24: Opinion AG – VAT Implications of Transfer Pricing Adjustments in Car Distribution Cases

Stellantis Portugal bought cars from General Motors group manufacturers and sold them to independent dealers, who then sold to customers.
Dealers repaired factory defects and invoiced Stellantis, including VAT; Stellantis then passed these costs (including its own) to the manufacturers, adjusting the car prices accordingly.
The Portuguese tax authority considered these adjustments as domestic services subject to VAT, leading to additional VAT assessments.
Stellantis appealed, and the case was referred to the EU Court of Justice.
Advocate General Kokott concluded that if profit adjustments are made via a variable purchase price for specific goods, it is a reduction of the taxable amount, not a taxable service under the VAT Directive.

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.