- Spørger is a cooperative enterprise.
- Businesses dealing in Spørger’s product range can become members by subscribing to cooperative capital.
- The general assembly can decide to allocate part of the annual surplus or transfer from reserves to members’ cooperative accounts based on their transactions with Spørger.
- Transactions include both purchases and sales.
- Members can sometimes withdraw their allocated cooperative capital, such as when they cease operations.
- The Tax Council determined that the payout of a member’s cooperative account, consisting of previous allocations, constitutes a supply for consideration.
- There is a direct link between Spørger’s transactions with members and the allocations/payouts from members’ cooperative accounts derived from accumulated surplus.
- Payouts are considered taxable consideration/price reductions.
- The portion of the allocation related to members’ supplies to Spørger is additional consideration for members’ supplies, increasing members’ sales VAT and Spørger’s purchase VAT.
- The portion related to Spørger’s supplies to members is considered a price reduction, decreasing Spørger’s sales VAT and members’ purchase VAT.
- Allocated amounts are included in the tax base when the general assembly approves the payout, based on the actual amounts paid, as this is when the member acquires the final right to the payout.
Source: info.skat.dk
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.
