VAT Treatment of Transfer Pricing Adjustments
The VAT treatment of intra-group transfer pricing adjustments has been debated in both practice and case law for several years.
The VAT treatment of intra-group transfer pricing adjustments has been debated in both practice and case law for several years.
Cooperation between different companies generally leads to a supply for consideration which is subject to VAT. An exception applies in the case of VAT groups.
EU Council Implementation Regulation 282/2011
A single-purpose voucher (SPV) is a voucher for which the place of the underlying supply of goods or services and the VAT due thereon are known at the time the voucher is issued. Each SPV transfer made by a taxable person acting in his own name is to be regarded as the supply to which the voucher relates.
On December 12, 2024, the Court of Justice of the EU (CJEU) passed judgment in a case concerning the VAT deduction of the purchase of intercompany, cross-border administrative services by a Romanian entity.