- AG Kokott’s Opinion on VAT and Transfer Pricing: On March 6, 2025, Advocate General Kokott issued an Opinion in the Högkullen AB case (C-808/23), addressing the interplay between transfer pricing and VAT, particularly focusing on the concept of “open market value.”
- Determining Open Market Value: The Opinion emphasizes that the open market value should be assessed for each individual service provided by a controlling holding company to its subsidiaries, rather than using a compound service approach, which lacks a clear market value.
- Cost Allocation Considerations: If the individual service values cannot be determined, only the VAT-related expenditures allocated to that year’s services should be considered, rather than all costs incurred by the holding company, impacting how open market value is calculated for VAT purposes.
Source
See also
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