Comments on ECJ C-808/23: VAT Treatment of Intra-Group Management Services by Holding Companies

• The CJEU ruled on the VAT treatment of intra-group transactions in case C-808/23 Högkullen.
• Högkullen AB, a Swedish parent company, provided management services to its subsidiaries.
• The Swedish tax authority challenged the pricing of these services, arguing they should be considered comprehensive sui generis services.
• The authority included all costs, including investment costs, in the VAT tax base.
• The CJEU concluded that services provided to subsidiaries are not inherently inseparable and can be assessed individually.
• The ruling was favorable to the taxpayer, allowing the use of the comparator method for pricing.

Source: mddp.pl

See also

• ECJ C-808/23 (Högkullen) – Judgment – Parent-subsidiary services cannot always be treated as a single supply – VATupdate
• Briefing Document & Podcast: Högkullen AB Case (C-808/23) – VAT, Normal Value, and Intra-Group Services – VATupdate

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Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.