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Interbank fee constitutes turnover

The Supreme Administrative Court has held that a card issuer’s transfer to an network operator of an amount corresponding to a cardholder’s payment less “billing credit” means that the issuer sells a service. The Court held that there was a legal relationship between the issuer and the network operator which entailed a reciprocal exchange of services where the payment in the form of “billing credit” constituted the actual equivalent of the service provided by the issuer to the network operator through the transfer of the nominal amount. There was therefore such a direct connection between the service and the received turnover that is required to be a turnover ( HFD 2022-01-07, case no. 4610-21 and the Swedish Tax Agency’s case comment HFD, case no. 4610-21 – interbank fee for card payments).

The ruling means that the Swedish Tax Agency’s position Fees for card payments will no longer be applied .

Source: skatteverket.se

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