On 15 January 2026 the Opinion of Advocate-General (AG) Kokott issued in Stellantis Portugal, S.A. v Autoridade Tributária e Aduaneira C-603/24, a case concerning VAT and transfer pricing adjustments. In her opinion AG Kokott encouraged the Court of Justice of the European Union (CJEU) to apply a principled approach to an issue that has given rise to much debate. Stellantis is the latest in a line of CJEU cases addressing the vexed intersection of VAT, intra-group arrangements and transfer pricing adjustments.
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