Transfer pricing adjustments are used in intra-group settlements to bring the transfer price into line with market conditions. The necessity to make adjustments is caused by the occurrence of circumstances during the year that led to a change in significant market conditions of the transaction. They are carried out e.g. by adjusting the prices of goods or services or the taxpayer’s income / costs.
It is worth considering when the correction, apart from the correct diagnosis in terms of transfer prices and classification to tax costs / revenues, is also associated with the correction of VAT settlements. This dilemma was the subject of a recently published individual interpretation
Source MDDP
