EU27 TAX RULING
Hypothetical Compliance Case: Intra-Group Sales, Artificial Demand and Inventory Write-Offs in the EU Author: Ryan Khouja 1. Hypothetical scenario A multinational company headquartered in Ireland, the Netherlands, Belgium or Luxembourg operates across the EU27 through local subsidiaries. The European headquarters sells machines to its subsidiaries using the same European VAT structure or intra-group invoicing model. The subsidiaries receive machinery even when there is no clear evidence of real market demand, customer orders, local sales forecasts or commercial necessity. After a reasonable period, the group declares that the machines are obsolete, commercially unsellable or technically outdated. The subsidiaries then scrap the machines, derecognise them from accounting records and book an impairment, inventory write-off or exceptional loss. 2. Core compliance question Could this structure contravene EU, national tax, accounting, VAT, transfer pricing or anti-avoidance...