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Latest EU VAT Developments on Intragroup Transactions and Transfer Pricing Adjustments

  • The CJEU ruled in the Arcomet Towercranes case that payments calculated using OECD transfer pricing methods may be considered remuneration for services subject to VAT.
  • The Advocate General’s opinion in the Stellantis Portugal case suggests that TP-based payments may fall within VAT scope, depending on the transaction structure.
  • Businesses must carefully assess the VAT implications of intragroup transactions and TP adjustments to avoid penalties, non-deductible VAT, and operational risks.
  • The article highlights the lack of uniform EU rules on VAT treatment of TP adjustments and the importance of recent CJEU guidance.

Source: grantthornton.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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