- The CJEU ruled on the valuation of services by holding companies in the Högkullen case.
- The case involved support services provided by a holding company to its subsidiaries in the real estate sector.
- The holding company charged subsidiaries on a cost-plus basis but did not include all overhead costs.
- The Swedish Tax Authorities argued that all costs, including overheads, should be included in the service value.
- The CJEU decided that intra-group services are not automatically a single supply and can have separate values.
- The Court emphasized the need for a market-based comparison rather than defaulting to cost-based valuation.
- The decision impacts how VAT is applied to overheads in intra-group services.
Source: essentiaglobalservices.com
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.
