On 12 December 2024, the European Court of Justice delivered its
judgment in the Weatherford Atlas Gip case (C-527/23). The case
further clarifies the link between VAT and Transfer Pricing
(TP) matters.
Facts
Weatherford Atlas Gip is part of the Weatherford group,
specializing in oilfield services. On June 6, 2016, Weatherford
Atlas Gip acquired Foserco SA (Foserco), a
Romanian company. Foserco (now Weatherford Atlas Gip) provides
auxiliary services for the extraction of oil and natural gas.
In 2015 and 2016, Foserco provided drilling services in Romania.
For this purpose, general administrative services - such as IT,
human resources, marketing, accounting, and consulting – were
purchased by Foserco from other related companies within the
Weatherford group established outside of Romania. The reverse
charge mechanism was applied. As these services are also provided
to other related companies within the Weatherford group, part of
the service cost was allocated to
