Supply Chain Academy session 2: Transfer pricing and indirect taxes

The points below outline several key considerations relevant to the topic discussed in the second part of the Supply Chain Academy.

• Integrate transfer pricing into your VAT and customs strategy from the start
  Transfer pricing (TP) policies directly influence VAT treatment, customs valuation, and the taxable base of cross‑border flows. Embedding TP early in supply chain design avoids inconsistencies, reduces compliance risk, and ensures coherent positions across tax domains. 
  
  
• Take ownership of your data to correctly assess VAT and customs impacts
  Accurate, complete, and well‑structured data is essential to determine whether TP adjustments fall inside VAT scope, affect customs value, or require corrective invoicing. Strong data governance enables defensible reporting, smoother audits, and consistent application of TP methodologies across indirect tax processes. 
  
  
• Acknowledge that CJEU cases address only the specific questions raised; many TP–VAT–customs interactions remain unresolved
  Recent CJEU decisions and opinions (e.g., Arcomet, Stellantis) provide valuable direction, but they address narrow legal questions. Significant uncertainty remains on how different types of TP adjustments should be treated for VAT and customs purposes. Future case law, administrative commentary, and EU‑level guidance will be needed to clarify these open points. 
  
  
• Move from reactive corrections to a proactive, documented TP–VAT–customs alignment
  A proactive framework supported by clear contracts, functional analyses, data monitoring, and scenario testing helps anticipate how pricing changes affect indirect tax outcomes. This reduces audit exposure, avoids year‑end surprises, and positions indirect tax as a strategic enabler rather than a corrective function.