Arcomet case C-726/23

The Arcomet judgment (C-726/23, 4 September 2025) clarifies the VAT treatment of intra-group transfer pricing adjustments. The Court held that such adjustments may constitute consideration for taxable services where they remunerate actual services supplied, and the right to deduct input VAT depends on the substantive and formal conditions set out in Articles 168 and 178 of the VAT Directive.
The ruling confirms that tax authorities may require additional documentation beyond the invoice to allow input VAT deduction but cannot be required to establish the necessity or appropriateness of those services in respect of taxable operations.