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CJEU Issues Judgment on VAT Treatment of Intra-Group Services Invoiced Under Transfer Pricing Arrangement

|Approved Changes|European Union-Romania
European Union-Romania

On 4 September 2025, the European Court of Justice (CJEU) issued a judgment concerning the VAT treatment of intra-group service payments in relation to transfer pricing adjustments to fall within a set profit margin range. The case involved Arcomet Towercranes SRL, a Romanian subsidiary, and its Belgian parent company, Arcomet NV, which had entered into a transfer pricing arrangement based on OECD guidelines. Under the agreement, an annual settlement invoice had to be issued by Arcomet Belgi…

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