- AG Kokott opined that transfer pricing adjustments for income tax are relevant for VAT only if they change the actual price paid or received for a supply.
- Adjustments that merely reallocate profits within a group, without altering the consideration, are not relevant for VAT.
- Intra-group price adjustments are corrections to the original supply price, not independent supplies of services for VAT purposes.
- Reimbursements after price reductions do not constitute a service, and there is no “negative consideration” in VAT.
- Profit reallocations via transfer pricing that do not reflect consideration for an economic activity are irrelevant for VAT.
Source: pwc.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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