A new perspective from the CJEU on transfer pricing adjustments and VAT – the Arcomet Case (C-726/23)

A new perspective from the CJEU on transfer pricing adjustments and VAT – the Arcomet Case (C-726/23)

Transfer pricing, Trochę o VAT

Continuing the TP and VAT series, in which we discuss the most important cases regarding intra-group settlements (see: Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT), this time we are looking at the Arcomet case (C-726/23), which introduces a new perspective on a well-known topic. The issue…

Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?

Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?

Corporate tax, Trochę o CIT, Trochę o VAT, VAT

Organised part of an enterprise Tax regulations define an organised part of an enterprise [hereinafter: OPE] as a set of assets – tangible and intangible, including liabilities – organisationally and financially separated within an existing enterprise, intended to perform specific business tasks, which could also constitute an independent enterprise performing these tasks on its own.…

Tax base for management services of subsidiaries by a holding company - CJEU judgment

Tax base for management services of subsidiaries by a holding company – CJEU judgment

Trochę o VAT

On 3 July 2025, the CJEU once again spoke on the VAT treatment of intra-group transactions – this time in judgment C-808/23 Högkullen. Factual state Högkullen AB, the Swedish parent company in the real estate management group, operated solely in the area of ​​managing subsidiaries and provided them with paid management, financial, personnel, etc. services.…

Supreme Administrative Court: The enforceability warrant must be served on the taxpayer’s legal representative

Supreme Administrative Court: The enforceability warrant must be served on the taxpayer’s legal representative

Trochę o VAT

The resolution of the Supreme Administrative Court (NSA) of 16 June 2025 (case no. III FPS 1/25) settles a dispute regarding the delivery of an enforceability warrant issued under Article 155b § 1 of the Act on Enforcement Proceedings in Administration. The NSA held that such a warrant must be served on the authorized representative…

Intra-group settlements under scrutiny by the CJEU - what does the Weatherford ruling mean for intra-group service acquisitions?

Intra-group settlements under scrutiny by the CJEU – what does the Weatherford ruling mean for intra-group service acquisitions?

Transfer pricing, Trochę o VAT

In the first article of our TP & VAT series (link: https://www.mddp.pl/intra-group-settlements-under-the-scrutiny-of-the-cjeu/ ), we outlined the general background to recent rulings by the Court of Justice of the European Union (CJEU) in this area. Today, we delve deeper into the topic by analysing the Weatherford judgment (Case C-527/23), which carries significant implications for the interpretation…

Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT

Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT

Transfer pricing, Trochę o VAT

The issue of intra-group transactions in the context of value-added tax (VAT) is increasingly attracting the attention of the Court of Justice of the European Union (CJEU). Recent cases underscore the importance of delineating the boundaries between direct tax (CIT) and indirect tax (VAT) regulations, as well as the significant practical implications that transfer pricing…