- Each service provided by a parent company to its subsidiary must be individually re-evaluated for VAT purposes, regardless of whether a total amount is invoiced.
- The Swedish Supreme Administrative Court clarified that the Tax Agency must first prove there is no comparable service on the open market before determining market value based on the provider’s own costs, even for intra-group services.
- The previous legal position from HFD 2014 ref. 40 regarding the burden of proof no longer applies.
- The Tax Agency’s previous stance on re-evaluation of intra-group services is not consistent with this ruling and will be withdrawn.
- The case involved a parent company providing various management and administrative services to subsidiaries, with compensation significantly lower than its costs, prompting a review of the VAT taxable base.
Source: www4.skatteverket.se
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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