VAT Tax Base in Intra-Group Transactions: Högkullen AB vs. Swedish Tax Authority Case Analysis

• The case involves a dispute between Högkullen AB and the Swedish tax authority regarding VAT assessment on intra-group services.
• Högkullen AB, a holding company, provides paid services to its subsidiaries, which are partially VAT-exempt.
• In 2016, the holding company invoiced its subsidiaries approximately 2.3 million SEK for services using a cost-plus method.
• The Swedish tax authority challenged the declared VAT base, claiming the invoiced amount was below market value.
• The tax authority recalculated the VAT base, estimating the holding company’s total expenses for 2016 at 28 million SEK.
• The first-instance court annulled the tax authority’s decision, stating not all expenses could be attributed to services for subsidiaries.

Source: mddp.pl

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.