Transfer Pricing Adjustments: Ongoing TP-VAT-CIT-WHT-PSI-Customs Risks at Year-End Closure

• Transfer pricing (TP) adjustments remain a complex and unresolved issue, generating increasing tax and customs risks, especially at year-end and with upcoming e-invoicing requirements.
• Recent EU and national developments, including the Stellantis Portugal case, highlight ongoing uncertainty about the VAT implications of TP adjustments made after year-end.
• The General Advocate’s opinion stresses that not all TP adjustments automatically affect VAT; the direct link to specific supplies and the nature of the original price are crucial.
• Each TP adjustment requires a case-by-case analysis, with consistent tax and accounting documentation needed to mitigate audit risks.
• There is still no simple, universal approach for handling TP adjustments in VAT, increasing operational risk for corporate groups.

Source: crido.pl

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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