Germany: Services provided by parent company to subsidiaries not “single supply” for VAT valuation purposes (CJEU judgment); other VAT developments

Recent VAT developments that may affect businesses in Germany

The Court of Justice of the European Union (CJEU) on July 3, 2025, held (C-808/23) that services provided by a parent company to its subsidiaries do not have to be treated under the Articles 72 and 80 of the EU Value Added Tax (VAT) Directive as a single (unique) supply in all cases, precluding the determination of their normal value in accordance with the comparative method provided for in the first sentence of Article 72 of the Directive.

Read a July 2025 report prepared by the KPMG member firm in Germany

Other recent value added tax (VAT) developments that may affect businesses in Germany include:

Joint and several VAT liability (CJEU judgment of July 10, 2025, C-276/24)
VAT-free universal postal services (CJEU judgment of June 19, 2025, C-785/23)
VAT exemption of cost-sharing groups (CJEU judgment of July 10, 2025, C-379/24 and C-380/24)
No adjustment of the VAT assessment basis in the event of insolvency of the "paying agent" (BFH, ruling from April 30, 2025, XI R 15/2
Changes due to the BEG IV and the JStG 2024 (BMF, letter dated July 8, 2025, III C 2 - S 7295/00005/003/080)
Electronic invoicing (e-invoicing) planned national reporting system (platform)

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Germany: Services provided by parent company to subsidiaries not “single supply” for VAT valuation purposes (CJEU judgment); other VAT developments

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