- The European Court of Justice clarified that internal administrative services within a group are not necessarily considered a single service for VAT purposes.
- In the case involving Högkullen AB, a holding company provided various taxable services to its subsidiaries, including management and finance.
- The Swedish tax authority believed the VAT basis should be all costs borne by the holding, as there were no comparable market services.
- The court stated that the services are not a single service but multiple individual services.
- Even if a single total price is charged, it does not affect the VAT assessment.
- The VAT basis for each service should be determined based on market prices, not as a single service without a comparable market price.
Source: ebnerstolz.de
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
- Join the Linkedin Group on ECJ/CJEU/General Court VAT Cases, click HERE
- VATupdate.com – Your FREE source of information on ECJ VAT Cases
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.
