On 17 September 2014, the European Court of Justice (ECJ) ruled in the Skandia America Corporation vs Swedish tax authorities case that recharges of bought-in costs or provided by financial services group companies to their branches and subsidiaries in other EU countries will be liable to a VAT charge.  Until this ruling, foreign subsidiaries were treated as combined with their holding companies, so no VAT due on any intra-group invoices was due.

This ruling creates a multi-billion charge across Europe as the subsidiaries will not be able to reclaim this VAT charge since they are not VAT registered themselves since financial services are exempt from VAT.