Are Transfer Pricing Adjustments Subject to VAT? Advocate General’s Opinion in C-603/24 Stellantis

Transfer pricing adjustments that correct the price are subject to VAT.
Merely incurring costs or receiving reimbursements under transfer pricing rules does not constitute a supply of services for VAT purposes.
The main issue is whether transfer pricing adjustments between related entities should affect VAT calculations.
Advocate General Kokott’s opinion is that, in principle, such adjustments do not automatically mean a VAT-taxable service is supplied.

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.