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CJEU Ruling on Högkullen Case: Intra-Group Services and VAT Tax Base Clarified

  • The article discusses a recent ruling by the Court of Justice of the European Union on intra-group services and VAT taxation.
  • The case involves the Swedish company Högkullen, which provides various services to its subsidiaries, all subject to VAT.
  • The Swedish tax authority challenged Högkullen’s method of calculating service fees, arguing it undervalued the services compared to market value.
  • The Court ruled that services provided by a parent company to its subsidiaries should not automatically be treated as a single service without a market value.
  • Each service, such as management or IT, can be considered independently if not closely linked.
  • The Court emphasized the need to attempt to determine a comparable market value before using a cost-based method for VAT purposes.

Source: mddp.pl

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.

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