The value-added tax implications of transfer pricing arrangements are becoming a hot topic, due to a string of recent European Court of Justice cases, including Arcomet Towercranes and Högkullen, as well as the UK case, JPMorgan Chase Bank N.A. Last month, an Advocate General opinion in Stellantis Portugal, S.A. v Autoridade Tributária e Aduaneira said the group’s Portuguese entity’s transfer pricing adjustments weren’t consideration for a separate supply of services.