# HIVE Faces $84.7 Million Swedish VAT Provision in Mining Dispute

By Riza Dagoc

Canonical URL: https://www.tokenpost.com/news/regulation/24010
Published: 2026-09-25T06:17:28.000Z
Updated: 2026-09-25T06:17:28.000Z

HIVE Digital Technologies recorded an $84.7 million noncash provision for a Swedish value-added tax dispute involving its Bitcoin (BTC) mining facilities, while seeking further review of the European Union legal questions at issue.

The provision totaled SEK 822 million for the quarter ended June 30, 2026. It includes SEK 769.6 million tied to issued or proposed Swedish Tax Agency decisions and SEK 52.4 million for later periods without issued decisions.

HIVE’s Swedish subsidiaries, Bikupa Datacenter AB and Bikupa Datacenter 2 AB, are challenging decisions that rejected their recovery of input VAT and sought repayment of previously refunded amounts, along with tax supplements and interest. The assessments cover decisions issued from Dec. 28, 2022, through April 27, 2026.

The companies appealed the initial decisions in February and March 2023 and challenged later decisions as they were issued. After losing in the Court of Appeal, HIVE filed applications for leave to appeal with Sweden’s Supreme Administrative Court on July 20.

HIVE has also initiated proceedings with the European Commission over what it describes as Swedish administrative courts’ refusal to refer unresolved EU-law questions to the Court of Justice of the European Union.

The central issue is whether the Swedish facilities provided computing capacity to identified customers or mined digital assets for HIVE’s own account. That classification determines whether the company can recover VAT paid on equipment, electricity and other operating costs.

HIVE Chief Financial Officer Darcy Daubaras said the provision significantly affected the company’s reported net loss. “Importantly, our reported net loss was significantly impacted by non-cash items, including the $84.7 million provision related to the ongoing Swedish VAT matter,” Daubaras said.

Interest continues to accrue on assessed amounts, and HIVE said its eventual exposure may exceed the provision. The company’s Swedish facilities represented about 5% of its global daily hashrate services as of June 30.

A European Commission or Court of Justice review could influence how European Union jurisdictions treat crypto-mining and hashrate-hosting businesses. The Court of Justice has addressed VAT treatment for Bitcoin-to-fiat exchanges, but that decision did not resolve whether supplying computing capacity for mining receives the same treatment.

HIVE’s next stated legal step is its request for leave to appeal before Sweden’s Supreme Administrative Court.