- AG Kokott’s Opinion: Advocate General Kokott issued an opinion on the ‘open market value’ and single vs. multiple supplies in the Högkullen AB case (C-808/23).
- Case Background: The case involves a holding company providing various intra-group services to subsidiaries, with disputes over VAT treatment and the determination of ‘open market value.’
- Key Issues: The opinion addresses whether services should be considered unique or multiple for VAT purposes and if shareholder and capital-raising costs should be included in the taxable amount.
- AG Kokott’s Stance: AG Kokott argues that distinct services should be assessed separately for VAT, and only expenditures subject to VAT should be included in the ‘open market value.’
- Implications: The opinion highlights complexities in VAT treatment of transfer pricing charges and intra-group transactions, with potential impacts on exemptions and place of supply rules.
Source
See also
- Join the Linkedin Group on ECJ/CJEU/General Court VAT Cases, click HERE
- VATupdate.com – Your FREE source of information on ECJ VAT Cases
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