ECJ Rules Against Automatic Single Supply Treatment for Intra-Group Management Services

• The European Court of Justice ruled on 3 July 2025 that intra-group management services should not automatically be treated as one supply for VAT purposes
• The case involved a Swedish parent company providing various business services to subsidiaries using a cost-plus pricing method while excluding shareholder costs
• The Swedish Tax Agency disagreed with the pricing and determined the taxable amount as total costs borne by the parent company
• The ECJ determined that multiple service elements must be assessed individually to see if they form distinct supplies or one single indivisible economic supply
• The ruling clarifies that tax authorities cannot automatically treat all parent company management services as a single non-comparable supply, providing important guidance for multinational groups on VAT treatment

Source: schjodt.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.

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