- • In the Stellantis case (C‑603/24), the CJEU ruled that transfer pricing adjustments are not always subject to VAT. • The Court held that, in this case, the TP adjustment was just a correction of the agreed price for the supply of vehicles, not payment for a separate service. • There was no direct link between a specific service and the TP adjustment, and no other agreement showing such a relationship. • TP adjustments can either change the VAT taxable amount or count as payment for a separate supply/service, depending on the facts. • Companies should review their transfer pricing policies for VAT implications to avoid penalties and interest.
Source: vanoers.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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