Advocate General Kokott’s Opinion C‑603/24 clarifies how intra‑group transfer price adjustments interact with VAT. The opinion states that such adjustments are not automatically a separate VAT supply, but may alter the taxable amount under Articles 73 and 90 of the VAT Directive if they reflect a variable purchase price agreed upfront. Only when an actual service for consideration exists is a separate supply considered.
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Key Takeaways
The opinion clarifies that such adjustments are not automatically a separate VAT supply; they only affect the taxable amount if they reflect a variable purchase price agreed upfront.
When the adjustment reflects a variable purchase price agreed upfront, it changes the taxable amount under Articles 73 and 90 of the VAT Directive.
Only if an actual service for consideration exists; otherwise it is not a separate supply.
The Portuguese tax authority is cited as viewing the purchaser as having supplied a service to the seller when the purchase price is adjusted.
Primary source
Read the full article at LinkedInThis summary was published on VATfaqs.com on 15 January 2026. It relates to VAT developments in European Union. The original source is LinkedIn.
