The article reviews recent EU Court of Justice rulings that clarify the VAT treatment of transfer‑pricing adjustments in intragroup transactions. It explains that payments calculated under OECD methods may be treated as VAT‑subjected remuneration for services, while unilateral profit allocations are generally outside VAT scope. The piece also highlights the pending Stellantis Portugal opinion and the need for businesses to document services and support evidence to secure VAT recoverability.
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Deloitte Luxembourg · 10 days ago
On 13 May 2024, the CJEU ruled that contractual price adjustments in intragroup transactions are not considered a supply of services for VAT purposes, meaning such adjustments fall outside the scope of VAT. The decision applies across the EU, including Portugal and Luxembourg, and underscores the need for case‑by‑case assessment of transfer pricing adjustments. The ruling does not change VAT rates or thresholds but clarifies the treatment of these adjustments.
Law360 · 15 days ago
The EU's top court ruled that intercompany pricing adjustments between the former General Motors unit and Stellantis do not alter VAT liability, meaning the Portuguese government should not have increased the VAT bill for Stellantis. The decision clarifies that such pricing shifts are not subject to VAT adjustments.
VatCalc · 23 days ago
EU finance ministers endorsed an amendment to Regulation (EU) No 904/2010 that will allow OLAF and EPPO to query Member State VAT systems, but the amendment restricts access to read‑only, case‑by‑case searches and bans bulk extraction or AI analysis. The measure is pending Parliament approval, likely in July 2026, and will be routed through VIES, CESOP and Eurofisc channels.
Global VAT Compliance · 23 days ago
The European Commission’s proposed EU bill would require member states to share VAT data with anti‑fraud agencies, but Spain has raised objections over data access provisions and inconsistencies. The proposal, introduced in November, seeks to strengthen cooperation against VAT fraud, which the Commission estimates costs the EU €90 billion annually. Spain plans amendments ahead of the upcoming EU finance ministers meeting.
SAFT Validator · about 1 month ago
The article examines the ownership of the SAF‑T compliance process across European organisations, outlining the roles of tax, finance, IT, and external advisers. It highlights the challenges of multi‑country mandates and proposes a three‑layer model—accountability, operational ownership, and execution—to streamline responsibilities. The piece also notes the expanding SAF‑T requirements, such as Bulgaria’s 2026 launch, and stresses the importance of clear ownership for accurate, timely filings.
e-Invoice.app · about 1 month ago
This guide explains how to design an e‑invoicing RFP that accommodates the growing number of mandates worldwide, highlighting the EU’s ViDA deadline of July 2030 for intra‑EU B2B e‑invoicing and outlining five compliance models. It offers practical steps for mapping mandates, drafting model‑specific questions, and evaluating vendors on regulatory adaptability, integration, and security.
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Key Takeaways
The CJEU held that payments calculated using an OECD transfer‑pricing method and charged by a principal to an operating company may constitute remuneration for services within the scope of VAT, provided there is a contractual arrangement and a direct link between services and remuneration.
The AG stated that TP adjustments that reflect a separate supply of services for consideration fall within VAT scope, whereas unilateral profit adjustments made solely for income allocation between jurisdictions do not.
Primary source
Read the full article at Grant ThorntonThis summary was published on VATfaqs.com on 16 February 2026. It relates to VAT developments in European Union. The original source is Grant Thornton.
