Request for a preliminary ruling from the Supremo Tribunal Administrativo (Portugal) lodged on 16 September 2024 – Stellantis Portugal, S.A. v Autoridade Tributária e Aduaneira

(Case C-603/24, Stellantis Portugal)

(C/2024/7155)

Language of the case: Portuguese

Referring court

Supremo Tribunal Administrativo

Parties to the main proceedings

Applicant: Stellantis Portugal, S.A.

Defendant: Autoridade Tributária e Aduaneira

Question referred

Must Article 2 of the Sixth VAT Directive (Sixth Council Directive 77/388/EEC of 17 May 1977  (1) on the harmonisation of the laws of the Member States relating to turnover taxes – Common system of value added tax: uniform basis of assessment), as worded in the version in force at the time of the facts, be interpreted as meaning that the concept of the supply of services effected for consideration contained in that provision includes an adjustment of the sale price of vehicles which is duly provided for and determined in a contract concluded between the parties, in order to achieve a minimum profit margin, and which is documented by means of a credit or debit note issued to the applicant/appellant by the European manufacturers of the General Motors group?

(1)   OJ 1977 L 145, p. 1.