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Authors: Guido De Wit, Sören Vandeweyer, Jan Van Cauwenberghe

Transfer pricing adjustments, linked to actual intra-group services supplied, are subject to VAT

In a highly anticipated judgment, the Court of Justice of the EU ruled on 4 September 2025 that transfer pricing adjustments in the context of intra-group transactions are subject to VAT provided there is a direct link with a service that is actually supplied.