- It is not compatible with EU VAT Directive articles 72 and 80 to always treat services provided by a parent company to its subsidiaries as a single supply, excluding the use of the comparative method for market value determination.
- When a parent company actively manages its subsidiaries by providing various services (e.g., management, finance, property management, investments, IT, HR), these should be considered as separate supplies, not a single composite service.
- Each service must be individually assessed to determine if the compensation is below market value, even if invoiced as a lump sum.
- The primary method for determining market value is to compare with similar services on the open market; if no comparable service exists, the cost price should be used.
- These principles guide whether there is a basis for reassessment of the VAT taxable amount.
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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