VAT and Transfer Pricing: An Analysis of the Most Recent and Controversial Interactions

In this note, the authors comment on the growing intersection between direct and indirect taxation, with transfer pricing and VAT as its protagonists. Through two landmark European cases, Arcomet Towercranes (C-726/23) and Stellantis Portugal (C-603/24), the analysis maps the boundaries that European courts are drawing around intra-group price adjustments and what those boundaries signal for multinationals navigating an increasingly contentious regulatory landscape.