VAT, Intra-Group Arrangements and Transfer Pricing Adjustments

First published in Irish Tax Review Issue 1, 2026.

In the recent issue of the Irish Tax Review, Philip McQueston, Of Counsel, and Saumya Sadanand, Tax Advisor, explore the evolving interaction between VAT and Transfer Pricing (TP), with a particular focus on recent guidance from the Court of Justice of the European Union (CJEU).

The article analyses a series of influential CJEU decisions, including Arcomet Towercranes, Weatherford Atlas, Högkullen and the Advocate General’s Opinion in Stellantis, which together provide important clarification on the VAT implications of TP adjustments, intra-group management services and VAT deductibility.

Key themes addressed in the article include:

• whether TP adjustments should be regarded as consideration for a supply of services or treated as outside the scope of VAT
• the potential for a more principled framework to emerge on the VAT treatment of TP adjustments, following the Advocate General’s Opinion in Stellantis
• the documentation and substantive requirements for recovery of VAT on intra-group transactions
• the valuation and characterisation of intra-group management services for VAT purposes

The article highlights the importance of proactively considering VAT implications when structuring intra-group arrangements and drafting inter-company agreements, particularly where VAT exempt activities are involved.

For more information, please contact Philip McQueston, Of Counsel, Saumya Sadanand, Tax Advisor, or any member of the Tax team.

Date published: 1 April 2026