10.09.2025

ECJ on VAT treatment of transfer pricing adjustments

With its decision in the case SC Arcomet Towercranes(C-726/23) published on 4 September 2025, the ECJ takes a stance on VAT effects of transfer pricing adjustments (“TP adjustments”) for the first time. Description The SC Arcomet Towercranes SRL (subsidiary) is part of the Arcomet group. The Romanian subsidiary buys or rents cranes for selling or […]

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01.12.2021

Transfer Pricing Guidelines 2021

Almost a year after the publication of the draft Transfer Pricing Guidelines, on 7 October 2021 the Austrian Federal Ministry of Finance has finally issued the new Austrian Transfer Pricing Guidelines (ATPG 2021 or Guidelines). Being an extensive revision of the Transfer Pricing Guidelines from 2010 (TPG 2010), the ATPG 2021 aim at reflecting BEPS-project […]

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