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Advocate-General: Transfer Pricing Adjustments for Intra-Group Goods Likely Subject to VAT Compliance

  • Advocate-General Kokott advised that transfer pricing (TP) adjustments for intra-group supplies of goods may fall within the scope of VAT.
  • If the European Court follows this advice, businesses could face significant new VAT compliance obligations.
  • Three possible VAT scenarios for TP adjustments: no VAT, VAT as a price adjustment for goods, or VAT as consideration for separate services.
  • The Stellantis Portugal case will determine if TP adjustments for previously supplied goods are subject to VAT, following earlier rulings on services.
  • Businesses should carefully assess the VAT and compliance implications of TP adjustments.

Source: loyensloeff.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.



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