- Högkullen AB was a Swedish parent company providing services to its subsidiaries.
- Subsidiaries were partially VAT exempt and couldn’t fully recover input tax.
- Högkullen charged subsidiaries on a cost-plus basis.
- Swedish tax authorities considered Högkullen’s intra-group supplies a single supply with consideration less than open market value.
- Advocate General concluded that Högkullen’s services were separate and comparison prices could be ascertained.
- AG concluded that open market value couldn’t be determined by adding all of Högkullen’s expenditure.
- Only VAT-subject expenditure should be considered, allocated to output services, with capital costs apportioned.
Source: taxscape.deloitte.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.
