- Advocate General Juliane Kokott issued an Opinion in case C-603/24, Stellantis Portugal, addressing the VAT treatment of transfer pricing adjustments for corporate income tax purposes.
- The case involves whether adjustments to vehicle sale prices within the General Motors Group, documented by credit or debit notes, constitute a “supply of services for consideration” under the VAT Directive.
- Kokott opined that mere price adjustments do not generally qualify as a supply of services for VAT purposes.
- The VAT relevance of profit adjustments depends on their nature and method; only separate, genuine supplies of services for consideration are taxable for VAT.
- The Opinion provides interpretative guidance on the complex interaction between transfer pricing and VAT rules in the EU.
Source: ey.com
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"
- ECG T-96/26 (TellusTax Advisory) – Questions – VAT deductions in the event of different VAT treatment between Member States
- VIDA Measures applicable from 1 January 2027
- Agenda of the ECJ/General Court VAT cases – 7 Judgments and 2 Hearings till March 25, 2026
- Comments on T-638/24: Double dip alert – an incorrect invoice can create multiple VAT liabilities
- VAT IOSS Scheme: Intermediary Registration Available from April 2026 for Non-EU Businesses
