- The Advocate-General advised that transfer pricing adjustments within intra-group services may fall under VAT.
- This opinion could lead to additional compliance obligations for businesses if adopted by the European Court.
- Businesses should assess VAT implications and compliance requirements related to transfer pricing adjustments.
- The VAT treatment of transfer pricing adjustments is crucial for multinational companies.
- There is debate on whether these adjustments are part of the consideration for goods or services or outside VAT scope.
- If VAT applies, businesses may face significant compliance tasks, such as credit invoices and VAT return corrections.
- Some EU countries have issued guidelines on the interaction between transfer pricing adjustments and VAT.
- The Arcomet case involves a dispute over whether transfer pricing adjustments are considered remuneration for services.
Source: loyensloeff.com
See also
- ECJ C-726/23 (Arcomet Towercranes) – AG Opinion – Transfer Pricing Adjustment for intra-group services subject to VAT; documentation required
- Briefing Document: Advocate General’s Opinion in Case C-726/23 (SC Arcomet): VAT, Transfer Pricing and Intra-Group Services
- Join the Linkedin Group on ECJ/CJEU/General Court VAT Cases, click HERE
- VATupdate.com – Your FREE source of information on ECJ VAT Cases
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.
