The Advocate General’s opinion in the Stellantis Portugal case (C‑603/24) clarifies that transfer pricing adjustments between group companies are to be treated as adjustments to the original prices of earlier sales, not as separate repair services. Consequently, corrective invoices must be issued and the VAT taxable base of those earlier supplies must be adjusted. The final CJEU judgment is expected later in 2026.
The Advocate General concluded that transfer pricing adjustments are adjustments to the original prices of earlier sales, not separate repair services.
The opinion was published on 15 January 2026.
Corrective invoices must be issued and the VAT taxable base of the earlier supplies must be adjusted.
The final judgment is expected later in 2026.
This summary was published on VATfaqs.com on 16 January 2026. It relates to VAT developments in Portugal. The original source is Meijburg.
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LinkedIn · 11 days ago
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Bloomberg Tax · about 2 months ago
The article examines how transfer pricing adjustments can trigger VAT when they are considered payment for goods or services, citing the recent Stellantis Portugal Advocate General opinion. It highlights the need for multinationals to conduct structured reviews, document economic rationale, and maintain evidence to mitigate VAT risks, especially in finance and insurance sectors.
Bloomberg Tax · about 2 months ago
Bloomberg Tax’s commentary discusses how transfer pricing adjustments can create VAT exposure, citing recent ECJ cases and a Stellantis Portugal Advocate General opinion. It explains that adjustments tied to specific goods or services may be subject to VAT, while purely profit‑based adjustments may not. The article advises multinationals to conduct structured reviews and maintain documentation to mitigate risks.
Bloomberg Tax · about 2 months ago
The Advocate General opinion in the Stellantis Portugal case highlights uncertainty over whether transfer pricing adjustments constitute separate supplies of services and thus trigger VAT. The article reviews recent ECJ cases, outlines the need for structured VAT reviews, and stresses the importance of documentation for multinationals, especially those in finance and insurance sectors.
