On 13 May 2026, the Court of Justice of the European Union (CJEU) issued its judgment in the case Stellantis Portugal, S.A. v Autoridade Tributária e Aduaneira (Case C 603/24), on whether intra-group transfer pricing adjustments should be subject to VAT. The case involved Stellantis Portugal, S.A., as the legal successor of Opel Portugal, Lda. (formerly part of the General Motors group). The group used a transfer pricing agreement to ensure that the Portuguese distributor maintained a specif…