29
Jan
If the CJEU follows Advocate General Kokott's opinion in the Stellantis case (C-603/24), delivered on 15 January 2026, this will have significant implications for intragroup VAT practices.
Background
The VAT treatment of transfer pricing (TP) adjustments continues to present difficult challenges, as discussed in our previous newsflash.
Two recent rulings (C-808/23 and C-726/23) of the Court of Justice of the EU (CJEU) addressed this issue but did not provide a principled answer on the VAT consequences of TP adjustments.
Stellantis: Advocate General proposes VAT treatment for common...