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Case C-808/23, Högkullen: Judgment of the Court (First Chamber) of 3 July 2025 (request for a preliminary ruling from the Högsta förvaltningsdomstolen – Sweden) – Högkullen AB v Skatteverket (Reference for a preliminary ruling – Taxation – Common system of value added tax (VAT) – Directive 2006/112/EC – Article 72 – Open market value – Article 80 – Revaluation of the taxable amount – Parent company providing services to its subsidiaries in the context of actively managing them – Determination of the open market value)
ECLI:EU:UNKNOWN:62023CA0808
62023CA0808
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Official Journal of the European Union
C series
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C/2025/4557
(Case C-808/23,
(1)
Högkullen)
(Reference for a preliminary ruling - Taxation - Common system of value added tax (VAT) - Directive 2006/112/EC - Article 72 - Open market value - Article 80 - Revaluation of the taxable amount - Parent company providing services to its subsidiaries in the context of actively managing them - Determination of the open market value)
(C/2025/4557)
Language of the case: Swedish
Referring court
Parties to the main proceedings
Appellant: Högkullen AB
Respondent: Skatteverket
Operative part of the judgment
Articles 72 and 80 of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax
must be interpreted as precluding the services provided by a parent company to its subsidiaries in the context of the active management of those subsidiaries from being, in all situations, regarded by the tax authority as constituting a single supply which precludes the open market value of those services from being determined using the comparison method laid down in the first paragraph of Article 72 of that directive.
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(1) OJ C, C/2024/1846.
ELI: http://data.europa.eu/eli/C/2025/4557/oj
ISSN 1977-091X (electronic edition)
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