- VAT implications of Transfer Pricing (TP) adjustments are often overlooked by taxpayers, despite their potential impact on VAT obligations.
- TP adjustments aim to replicate conditions that would exist between independent parties, while VAT regulations focus on consideration received for a supply.
- Determining the VAT consequences of TP adjustments requires examining whether they can be considered as consideration for a supply and if a direct link exists between the adjustment and the supply.
- Each Member State may choose to follow non-binding recommendations or implement their own measures regarding TP and VAT.
- Recent developments, such as tax rulings from the Italian Revenue Agency, highlight the importance of evaluating TP adjustments’ VAT implications on a case-by-case basis and seeking professional advice for compliance.
Source Deloitte
