Transfer pricing and value added tax in the European Community : is there room for interaction and, if so, where?

This article analyses (1) whether there is room for interaction between transfer pricing and indirect tax (in particular, VAT) with regard to their respective valuation principles and (2) if there is room for such interaction, where such interaction can be found and whether it is recommended. The author concludes that in dealing with a transaction between associated enterprises, as a general principle there should be no room for interaction between the two fundamental valuation rules adopted for corporate tax income and VAT purposes. The different structure, purpose and principle of the two taxes justify the two rules, namely the arm's length principle and the subjective value.