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The VAT review for May 2025

VAT developments concerning transfer pricing adjustments, tripartite arrangements and the Tour Operators Margin Scheme are examined in this month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).

VAT and transfer pricing adjustments

There have long been questions over the VAT treatment of transfer pricing adjustment payments between related entities. Do such payments amount to consideration (or an adjustment of consideration) for VAT purposes or do they fall outside the scope of VAT? The issue has been considered on a number of occasions most recently by the VAT Expert Group in a 2018 report in which it recommended that transfer pricing adjustments should be considered as outside the scope of VAT where both parties have a full...

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