Comments on ECJ C-808/23: Intra-Group Charges Valuation

• Högkullen AB, a Swedish real estate management parent company, provided services to its VAT-exempt subsidiaries on a cost-plus basis, but did not account for certain shareholder and accounting costs when calculating intra-group charges.
• The Swedish tax authorities argued that Högkullen’s intra-group supplies constituted a single supply with a consideration below the open market value, which should equal at least the full cost of providing the service due to the lack of comparable market prices.
• The Advocate General concluded that Högkullen’s services were distinct, suggesting that market comparison prices could be determined, and emphasized that only VAT-subjected expenditures should be considered in calculating the open market value, with appropriate allocation for capital costs.

Source: taxscape.deloitte.com

See also

• ECJ C-808/23 (Högkullen) – AG Opinion – Management services from a holding company to subsidiaries can have comparable values under Article 72

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