Giles Salmond (Stewarts) considers the impact of a recent CJEU judgment on the nature and valuation of intra-group management services.
It is usually straightforward to work out the VAT due on the supply of goods or services or the importation of goods based on the price paid by one party to the other for the supply or importation in question. However where the parties are connected and input tax is not fully recoverable the VAT code permits the tax authorities to look at the open market value (OMV) to determine the VAT payable rather than that agreed by the connected parties who may often adopt direct tax transfer pricing methodologies to justify the price payable. The recent judgment of the CJEU in Högkullen AB v Skatteverket (Case C-808/23) considers the nature and valuation of intra-group management services.
The background
A Swedish holding company Högkullen (which I...
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Giles Salmond (Stewarts) considers the impact of a recent CJEU judgment on the nature and valuation of intra-group management services.
It is usually straightforward to work out the VAT due on the supply of goods or services or the importation of goods based on the price paid by one party to the other for the supply or importation in question. However where the parties are connected and input tax is not fully recoverable the VAT code permits the tax authorities to look at the open market value (OMV) to determine the VAT payable rather than that agreed by the connected parties who may often adopt direct tax transfer pricing methodologies to justify the price payable. The recent judgment of the CJEU in Högkullen AB v Skatteverket (Case C-808/23) considers the nature and valuation of intra-group management services.
The background
A Swedish holding company Högkullen (which I...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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