Court of Justice 6 March 2025, C-808/23 (Högkullen AB v Skatteverket.)

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The Advocate General's opinion addresses the legal dispute regarding the VAT treatment of services provided by a holding company to its subsidiaries, specifically whether the taxable amount should reflect the open market value or the actual consideration paid. The opinion highlights the complexities arising from the Court of Justice's previous case law, which requires holding companies to charge for management services to be recognized as taxable persons, and questions the appropriateness of including all of the holding company's expenditures in determining the taxable amount. Ultimately, the opinion seeks clarification on the compatibility of the Swedish tax authority's approach with the VAT Directive, particularly concerning the valuation of intra-group services.AI