Loss-making trip sale gives no VAT refund; tax base is zero

A travel firm that sells a trip at a loss stays inside the margin scheme and owes no VAT on that sale, but it also gets nothing back.Skatteverket Under the special scheme for travel agents (vinstmarginalbeskattning, VMB), the taxable amount is the firm's margin: the difference between the consideration received for the trip and the cost of goods and services bought in from other taxable persons for the direct benefit of the travellerSkatteverket (19 kap. 5 § mervärdesskattelagen (2023:200), cf. article 308 of the VAT Directive). That scheme applies even where the calculation produces a negative margin.Skatteverket

A negative margin gives the seller no right to a VAT refund (C-565/24, P-GmbH & Co. KG).Skatteverket The resulting loss also cannot be set against a profit made on another trip saleSkatteverket: each sale stands on its own. Where the margin is negative, the taxable amount is therefore 0 kronorSkatteverket, and no output VAT arises on that transaction.Skatteverket

The surrounding mechanics are unchanged. The rate to apply is the standard rate (normalskattesatsen) of 25 per cent. The firm's compensation for VAT is excluded from the consideration when the margin is computed (19 kap. 6 § ML).Skatteverket Input VAT relating to acquired goods and services that are for the direct benefit of the traveller is not deductibleSkatteverket, and supplying travel services does not confer a right to a refund of such input VAT under 14 kap. 7-9 §§ or 36 and 37 §§Skatteverket (19 kap. 8 § ML).

Invoicing and bookkeeping follow the scheme's special rules. A firm applying VMB need not state the VAT amount or the basis for its calculation on the invoiceSkatteverketSkatteverket, but the invoice must carry a specific note that VMB is applied.Skatteverket To compute the taxable amount per trip, the firm should keep bought-in costs and trip revenue separately identifiable in its accounts, covering the goods and services for the direct benefit of the traveller during the trip. The separation matters because only bought-in components enter the marginSkatteverket; services the firm produces itself are broken out and taxed under the general rulesSkatteverket.

One elective way out remains. Where the traveller is a taxable person with a right of deduction or refund of input VAT, the travel firm may instead apply the general provisions to that supply (19 kap. 10 § ML).Skatteverket A firm regularly selling at a loss to business customers should compare that route with a margin of zero under VMB, keeping the customer's VAT registration number on file to evidence that the general provisions were available.

Legal basis: 19 kap. 5, 6, 8 and 10 §§ mervärdesskattelagen (2023:200), articles 306–308 of the VAT Directive (2006/112/EG), and CJEU case C-565/24 (P-GmbH & Co. KG).