Comments on ECJ C-726/23 (Arcomet): From Accounting Entry to Taxable Event – The Acromet Case and VAT-TP Implications

• The phrase “just an accounting entry” was used to downplay transfer pricing adjustments.
• The Acromet case highlights the importance of understanding the substance behind numbers.
• The CJEU’s decision on the case is pending, with implications for VAT and transfer pricing clarity.
• The case involves invoices from Arcomet Belgium to its Romanian subsidiary, challenged by Romanian tax authorities.
• The CJEU was asked to determine if these adjustments are a supply of services under EU VAT law.
• Documentation is crucial for VAT deductions, requiring more than just invoices.
• Transfer pricing adjustments can trigger VAT obligations if they reflect real services.
• Fernando Matesanz warned in 2015 about the VAT implications of transfer pricing adjustments.

Source: rsm.global

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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