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Obligations of taxable persons EU VAT case law

37 cases of the Court of Justice and the General Court of the European Union on this point of VAT law, from 1996 to 2026.

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Under each case, what the Court decided, from its summary. The summaries are AI-generated and are not official documents: open the case for the Court’s own text.

C-544/24 Nekilnojamojo turto valdymas

Judgment · 30 April 2026

Proportionality of default interest on VAT arrears

The first question is inadmissible because Article 50 does not apply while the criminal proceedings are pending with no final conviction or acquittal. On the second, default interest on VAT arrears is preventive and compensatory, not punitive, so Article 49(3) does not apply, subject to verification by the referring court. Proportionality does not preclude a statutorily fixed rate with no power to reduce, disapply part, or remit outside exhaustively defined cases, including interest accruing during audit and litigation. Confirms that fixed statutory VAT default interest, without modulation for culpability or gravity, survives proportionality review, and that the absence of discretion is itself a safeguard of equal treatment and legal certainty.

C-605/23 Ati-19

Judgment · 3 July 2025 · Bulgaria

Judicial review of provisional sealing of business premises

Article 47 precludes such rules. Interim judicial protection is not effective if the court cannot also examine, in fact and in law, whether the application is supported by arguments disclosing prima facie unlawfulness of the measure. Otherwise suspension could be refused even against a manifestly unlawful sealing. The national court must interpret domestic procedural law accordingly and, if that is impossible, disapply the provisions preventing such an assessment, Article 47 having direct effect. Confirms that sealing of premises for till receipt failures is an implementation of Articles 2 and 273 of the VAT Directive, so Charter guarantees apply to both imposition and immediate enforcement. Relevant to advisers in any Member State whose interim relief rules exclude a summary legality check for coercive VAT enforcement measures of a criminal nature.

C-733/23 Beach and bar management

Judgment · 3 July 2025 · Bulgaria

Cumulation of fines and sealing of premises for till receipt failures

Both national rules are precluded. Sealing plus an access ban is criminal in nature for Article 50 purposes because of its intrinsic severity, and it does not lose that character merely because it also serves a preventive aim, nor because it responds to 85 breaches taken together rather than one. Separately, a fine with a high statutory minimum, here nearly 200 times the VAT evaded per breach, breaches proportionality where the court cannot reduce or substitute it. Confirms and extends MV-98 to bulk offences.

C-501/24 Klinka-Geo Trans

Order · 2 May 2025 · Hungary

Refusing deduction where the transaction never took place, without testing knowledge of fraud

Ruling by order, the Court held that the Directive does not preclude a refusal made without any examination of the recipient's knowledge where the authority establishes that the transaction did not take place. The knowledge test belongs to cases where a real transaction is tainted by fraud elsewhere in the chain, not to cases where there was no supply at all. The Court declared itself manifestly without jurisdiction on the second question and the fourth and sixth questions manifestly inadmissible, and confirmed that the national court must disapply directions it considers contrary to clear case law without needing to make a prior reference. The distinction it draws is the one that decides many Hungarian and Romanian disputes.

C-278/24 Genzyński

Judgment · 30 April 2025 · Poland

Joint and several liability of company directors for VAT arrears

They do not preclude such a system, provided liability is confined to arrears arising during the director's term and to amounts unrecovered from the company, and provided the director can genuinely rebut the presumption by showing he exercised all due diligence in managing the company's affairs. The escape route must not be merely theoretical. But the mere fact that the exchequer was the company's sole creditor when permanent insolvency arose is not by itself a defence. Confirms Member States may attach personal VAT liability to directors on a rebuttable presumption of knowledge and influence, without proof of fraud or bad faith, following Herdijk.

C-164/24 Cityland

Judgment · 3 April 2025 · Bulgaria

Removal from the VAT register as a penalty for persistent non-compliance

Those provisions and principles preclude such legislation. Member States may, within their discretion under Articles 213 and 273, provide for removal from the VAT register, and the removal rules in Articles 363 and 369r concern only the special scheme numbers. But deregistration is a particularly severe penalty, close to a prohibition on trading, so it can only be imposed after a full examination of the nature and seriousness of the infringements, the taxable person's conduct, and the risk to revenue and fraud. Confirms that deregistration is available as an anti-fraud tool but only on a reasoned, individualised assessment, with lesser penalties considered first.

C-277/24 Adjak

Judgment · 27 February 2025 · Poland

Directors' joint and several liability and the rights of the defence

Exclusion of the potentially liable director from the company's assessment proceedings is permissible. At that stage liability is only a possibility, and participation could compromise confidentiality and delay collection. But the exclusion is lawful only if, in the subsequent joint and several liability proceedings, the director can effectively challenge the findings of fact and legal classifications made in the assessment proceedings and can access the tax authority's file, subject to the rights of others. Member States may keep assessment and derivative liability in separate tracks, but the second track must be a genuine opportunity to reopen the quantum and characterisation of the debt, not merely to test the statutory conditions of liability.

C-262/24 Pegazus Busz

Order · 12 February 2025 · Hungary

Evidence of fraud must be put to the taxable person, and a lower court may depart from binding directions

Ruling by order, the Court declared several of the questions manifestly inadmissible or answerable from existing case law. On the merits it held that Article 47 of the Charter requires the taxable person to have knowledge of, and to be able to debate on an adversarial basis before the national court, the evidence on which the administration relies to find participation in evasion. It further held that the primacy of EU law and Article 267 TFEU oblige the national court to set aside directions it considers contrary to EU law, without being required to make a preliminary reference first. Two points of real practical weight in fraud cases.

C-613/23 Herdijk

Judgment · 14 November 2024 · Netherlands

Director liability for unpaid VAT after failure to notify inability to pay

Article 273 does not preclude such a system, provided the director may rely on any circumstance showing the notification failure is not attributable to him, and not only force majeure. The possibility must not be purely theoretical. Nor is it precluded that liability attaches for one period while the director escapes liability for the immediately following period, because each notification period stands alone. Good faith and absence of fraud do not cure the missing notification. Confirms Member States may make company directors joint and several debtors for VAT under Article 273, extending Direktor na Direktsia (C-1/21) to procedural default. Relevant to directors and insolvency practitioners in the Netherlands and any Member State with comparable notification regimes.

C-537/22 Global Ink Trade

Judgment · 11 January 2024 · Hungary

Due diligence and the burden of proof in denying deduction

A lower court must disregard higher court rulings inconsistent with the Court's interpretation, whether given by judgment or reasoned order. An obligation merely to give reasons for departing is permissible. Refusal for lack of diligence assessed by circular is allowed only if the authority still proves, by objective evidence, fraud and the taxable person's knowledge. No complex, far-reaching checks on counterparties may be required. The authority must follow its own circular, which must be unequivocal and foreseeable. Establishing a circular invoicing chain alone is insufficient. Fraud must be accurately described, though not every operator identified. Relevant to traders facing Hungarian (and comparable) deduction denials based on supplier unreliability or "passive fraud".

C-418/22 Cezam

Judgment · 17 May 2023 · Belgium

Penalties calculated on gross VAT before deduction

Article 273 and those principles do not preclude such legislation, subject to the referring court's assessment of proportionality in the individual case. Neutrality is not infringed where the fine does not itself deny or hinder the right of deduction. Here input VAT was allowed of the authorities' own motion. EN.SA. is distinguished because there the output tax had been paid and no revenue was at risk, whereas here declaration and payment were withheld over a prolonged period. Confirms that Member States may compute VAT penalties on gross output tax rather than on the net amount payable, provided the right of deduction itself remains intact.

C-289/22 A.T.S. 2003

Order · 9 January 2023 · Hungary

Deduction refused for fraud, regulatory breaches up the chain and the taxable person's duty of care

By reasoned order under Article 99. Cost reduction is legitimate because refusal requires a wholly artificial arrangement whose sole or essential aim is a tax advantage contrary to the Directive. A breach of national sector rules is not itself proof of fraud, but may be one indication in an overall assessment. The authority must characterise the fraud and prove participation or knowledge, though not identify every perpetrator. Taxable persons need not verify upstream compliance, unless indications of irregularity call for greater care.

C-512/21 Aquila Part Prod Com

Judgment · 1 December 2022 · Hungary

Proving participation in carousel fraud and the limits of the duty of diligence

The authority cannot rely merely on the existence of a circular invoicing chain. It must accurately describe the constituent elements of the fraud, prove the fraudulent conduct and establish either active participation or that the taxable person knew or ought to have known, though it need not identify every operator. Where fraud indicators exist, greater diligence may be required, but not complex checks equivalent to the authority's own investigations. Food safety breaches cannot alone justify refusal, but may be one element among others. Relevant to any business facing deduction refusals in chain transaction cases, particularly in Hungary and in the food sector.

C-1/21 Direktor na Direktsia Obzhalvane i danachno-osiguritelna praktika

Judgment · 13 October 2022 · Bulgaria

Joint and several liability of a company director for the company's VAT debts

Article 273 and proportionality do not preclude such liability where the person is a manager or member of an executive body, acted in bad faith in making hidden distributions or transferring assets free of charge or below market value, there is a causal link with the company's inability to pay VAT, liability is capped at the depletion of assets, and it arises only subsidiarily after recovery from the company fails. Default interest may be included, but only interest attributable to the bad faith acts. Article 205 does not apply. The PFI Convention does not either. Relevant to advisers on directors' personal exposure for corporate VAT arrears in Bulgaria and other Member States with similar derivative liability rules outside Article 205.

C-154/20 Kemwater ProChemie

Judgment · 9 December 2021 · Czechia

Deduction where the true supplier is unidentified

Deduction must be refused, without proof of fraud or knowledge of fraud, where the true supplier has not been identified and the taxable person fails to show that the supplier was a taxable person. The qualification is that refusal is only permissible if, on the factual circumstances and the evidence produced, the information needed to verify that status is lacking. Taxable person status is a material condition and may follow from the facts, for example where the volume and price of supplies show the small business exemption cannot apply. Naming the supplier on the invoice is formal.

C-358/20 Promexor Trade

Judgment · 18 November 2021

Deregistration for VAT, continued trading, and the right to deduct that follows

The Court held that those provisions and principles do not preclude such national legislation, where the identification has been revoked because no taxable transactions were indicated in the returns filed for six consecutive months and the taxable person continues its activities notwithstanding the revocation, provided that the taxable person is able to re-register for VAT purposes and to deduct the input VAT paid. The Court added that the fact that the director of the taxable person is a partner in another company which is the subject of insolvency proceedings cannot, in itself, be relied on to refuse systematically the re-registration of that taxable person for VAT purposes. Identification is a formal requirement and not a substantive condition of the right to deduct, and the judgment keeps that distinction workable by making the compatibility of the national regime conditional on a real route back to registration.

C-281/20 Ferimet

Judgment · 11 November 2021 · Spain

Deduction where the invoice names a fictitious supplier under the reverse charge

Naming the supplier is a formal condition, but the supplier's status as a taxable person is a material one. Deduction must be refused where, on the facts and the evidence the taxable person produces, the information needed to verify that the true supplier was a taxable person is lacking, or where it is established to the requisite legal standard that the taxable person committed VAT fraud or knew or should have known the transaction was connected with such fraud. Neither a risk of revenue loss nor a tax advantage need be shown. Relevant to scrap, metals and waste traders and anyone self-billing under domestic reverse charges.

C-583/20 EuroChem Agro Hungary

Order · 21 October 2021 · Hungary

A minimum fine of 30% of 40% of the value of the goods for a transport declaration error

Ruling by order, the Court held that Article 273 and the principle of proportionality do preclude such legislation. Member States may impose obligations and penalties to ensure the correct collection of VAT and prevent evasion, but the sanction must not go beyond what is necessary. A fine with an absolute floor calculated on the value of the goods, without regard to the nature and gravity of the breach or to whether any revenue was lost, exceeds those limits. The third question referred was declared manifestly inadmissible for want of sufficient explanation. One of the clearest applications of proportionality to the reporting obligations that surround electronic freight monitoring.

C-935/19 Grupa Warzywna

Judgment · 15 April 2021 · Poland

Proportionality of automatic VAT penalties

Article 273 and the principle of proportionality preclude such a penalty where it applies without distinction to an error of assessment by both parties as to the taxable nature of the transaction, absent any evidence of evasion or loss of revenue, and to cases where those circumstances are absent. Member States may still penalise wrongly claimed deductions. The defect is the automatic calculation, which leaves the authorities unable to adjust the amount to the individual circumstances. Neutrality was not examined. Relevant to anyone facing fixed-rate surcharges on disallowed input tax or overstated refunds, in Poland and in other Member States with automatic percentage penalties.

C-712/17 EN.SA.

Judgment · 8 May 2019 · Italy

Circular fictitious invoicing, liability under Article 203 and proportionality of penalties

Both denial of deduction and liability of the invoice issuer are inherent in the Directive and may apply cumulatively to the same trader, even where the issuer acted in bad faith. However, Member States must allow the Article 203 liability to be adjusted where the issuer has, in sufficient time, wholly eliminated the risk of loss of tax revenue. A fine equal to the full amount deducted, imposed without regard to the output VAT paid and the absence of any Treasury loss, breaches proportionality and neutrality. Relevant to anyone facing assessments on carousel-style or round-tripping invoicing where the flows cancel out, including intra-group trading structures in energy and commodities.

C-672/17 Tratave

Judgment · 6 December 2018 · Portugal

Prior notice to the debtor as a condition for reducing the taxable amount

The Court held that neutrality and Articles 90 and 273 do not preclude such a prior notification requirement. It falls within the Member States' discretion over formalities, contributes to correct collection, prevention of evasion and elimination of the risk of revenue loss, and allows the State to act in time in the insolvency proceedings. The requirement is subject to not being excessively onerous, which the referring court must verify. No particular form is prescribed. The second question was not answered. On a claim for bad debt relief the domestic notification formalities operate as substantive preconditions rather than administrative afterthoughts, and they have to be evidenced contemporaneously.

C-69/17 Siemens Gamesa Renewable Energy România

Judgment · 12 September 2018 · Romania

Deduction of VAT on acquisitions made while the taxpayer was declared inactive

The Court held that the Directive precludes such a refusal where it is based on the sole ground that the acquisitions fell within the period of de-activation. Registration and notification duties under Articles 213 and 214 are formal requirements only. Deduction must be allowed provided the substantive conditions of Article 168 are met and the right is not invoked fraudulently or abusively. The date of the return or invoice is not decisive. The national court must verify that the authorities had the data needed to establish the substantive conditions. Businesses whose VAT numbers have been cancelled for non-filing, a common Romanian practice and mirrored elsewhere, can recover input VAT incurred during the inactive period once reactivated, provided the substantive conditions are shown and there is no fraud or abuse.

C-534/16 BB construct

Judgment · 26 October 2017 · Slovakia

Guarantee required on VAT registration where the director has links to a company with tax debts

Article 273 and Article 16 of the Charter do not preclude such a guarantee, provided it goes no further than necessary. That assessment is for the national court. Proportionality requires the amount to correlate with the future risk of non-payment and the earlier debts, and to reflect the person's actual role in both companies. Automatic calculation the taxable person cannot see or contest may exceed what is needed. Equal treatment is not breached because those linked to companies with tax debts differ from those with other debts. Articles 49 and 50 do not apply, as the guarantee is not a penalty. Confirms that Member States may make VAT registration conditional on security based on the registration applicant's directors' history, and that such security is not a penalty, so ne bis in idem and non-retroactivity arguments fail.

C-493/15 Identi

Judgment · 16 March 2017 · Italy

Discharge of VAT debts in personal bankruptcy

EU law does not preclude it. The procedure is subject to strict conditions: the debtor's estate must have been fully liquidated, creditors at least partly satisfied, the debtor must satisfy probity and good faith requirements, and a court examines each case with the tax authority able to be heard and to appeal. It is therefore not a general and indiscriminate waiver of VAT. Nor is it State aid because those excluded are not in a comparable situation, so there is no selective advantage. Confirms and extends Degano Trasporti beyond arrangements with creditors to personal bankruptcy discharge.

C-518/14 Senatex

Judgment · 15 September 2016 · Germany

Retroactive effect of invoice correction

Those provisions preclude such legislation. The correction has retroactive effect and the deduction belongs to the year the original invoice was drawn up. Holding a compliant invoice is a formal, not substantive, condition, and the trader here already held invoices and had paid the input VAT. Member States may penalise formal breaches under Article 273, but by fines proportionate to the offence, not by postponing deduction and charging late payment interest regardless of the circumstances. Removes the interest exposure that flowed from ex nunc correction rules where the only defect is a missing mandatory invoice detail such as the supplier's VAT identification number.

C-546/14 Degano Trasporti

Judgment · 7 April 2016 · Italy

Partial payment of VAT debts in an arrangement with creditors

They do not preclude such legislation. The procedure is not a general and indiscriminate waiver of VAT collection, unlike the Italian amnesty measures previously condemned. It requires liquidation of all assets, an independent expert's finding that bankruptcy would yield no more, a creditors' vote in which the State may vote against, and judicial validation after any objection by the State. Within those safeguards, partial payment of a VAT claim is compatible with the duty to collect VAT and to secure the EU's own resources. Confirms that insolvency law may write down VAT liabilities where the reduction reflects genuine insolvency and is tested by expert evidence, a creditor vote and judicial control, so VAT need not be treated as untouchable in restructuring and liquidation proceedings. Relevant to insolvency practitioners, restructuring advisers and tax authorities across Member States with composition, arrangement or scheme procedures.

C-424/14 Balogh

Order · 30 September 2015 · Hungary

Declaring the start of an activity below the small-business threshold, and the fine for not doing so

Ruling by reasoned order, the Court held that Article 213(1) does not preclude such an obligation. The duty to declare the start of an activity is an administrative requirement that Member States may impose on persons within the scope of the tax even where the exemption for small enterprises applies. Nor does EU law preclude a fine for failing to comply. It is for the national court to assess whether the penalty actually imposed complies with the principle of proportionality. A reminder that the small-business exemption relieves the charge, not the registration duties that let an administration monitor who is trading.

C-499/13 Macikowski

Judgment · 26 March 2015 · Poland

Obligations of the court enforcement officer as paying agent on compulsory sales

None of these provisions precludes the Polish mechanism. The officer is a mere intermediary collecting tax on the taxable person's behalf, not a person liable, jointly liable or a tax representative under Article 204. The scheme falls within Article 273. Personal liability with all his assets is proportionate only if the officer actually has all the legal means to discharge the obligation in time, which the national court must verify. The supplier retains its right to deduct and may claim repayment of any overpayment. Confirms that Member States may use third party collection agents under Article 273 without engaging the liability rules in Articles 193 to 205. Relevant to enforcement officers, insolvency practitioners and auctioneers in Member States operating similar withholding mechanisms, and to advisers on compulsory sales of land.

C-18/13 Maks Pen

Judgment · 13 February 2014 · Bulgaria

Deduction refused where the invoiced supplier did not make the supply

Deduction may be refused on those facts only subject to a twofold condition: the facts amount to fraudulent conduct, and the authorities establish by objective evidence that the taxable person knew or should have known that the transaction was connected with that fraud. The absence of resources, missing cost entries and false signatures are not in themselves enough. Courts that may raise national law points of their own motion must do the same for the EU fraud rule. Article 273 permits accounting requirements based on international standards, but a revenue recognition test for the time of supply is precluded. Useful where an assessment rests solely on the invoiced supplier's lack of substance or defective paperwork. Relevant to businesses buying subcontracted services and to advisers handling deduction denials in Bulgaria and other Member States using substance-based challenges.

C-271/12 Petroma Transports and Others

Judgment · 8 May 2013 · Belgium

Late correction of incomplete invoices and the right to deduct

Correction of defective invoices is not prohibited, but the decisive point is timing. Where the supplementary information reaches the authority only after the refusal decision has been adopted, deduction may be refused. Member States could, under the Sixth Directive, require particulars beyond the listed minimum, provided these are limited to what is necessary and do not make deduction practically impossible. Neutrality gives no right to a refund to the supplier. The services were actually performed, so the VAT was due and correctly paid. Confirms that the Pannon Gép window for regularising invoices closes when the authority takes its decision. Relevant to intra-group service and management charge arrangements, where lump sum invoicing without hours or unit rates remains a common audit target.

C-527/11 Ablessio

Judgment · 14 March 2013 · Latvia

Refusal to assign a VAT identification number

A number may not be refused solely because the applicant lacks the material, technical and financial resources for the declared activity, or because its shareholder has repeatedly obtained numbers for companies that never traded and were then transferred. Such refusal requires objective factors amounting to sound evidence that the number will probably be used fraudulently, assessed overall. Those circumstances may feed into that assessment. Whether the evidence was sufficient is for the national court. Relevant to advisers handling start-up and pre-trading registrations, holding structures and businesses whose promoters have incorporated multiple entities.

C-263/11 Rēdlihs

Judgment · 19 July 2012 · Latvia

Timber sales after a storm, economic activity and penalties for late VAT registration

Such supplies are exploitation of tangible property and so economic activity, provided they are made for the purpose of obtaining income on a continuing basis. The force majeure motive and the private acquisition of the forest are irrelevant, and the national court must weigh all circumstances, including active forestry management, duration, number of customers and earnings. A fine fixed at the VAT rate on the value supplied, where the person was not liable for the tax, may breach proportionality. The national court must assess the sum actually imposed and any fraud or circumvention. Confirms that one-off sounding disposals of natural produce can still be continuous exploitation, so advisers to landowners, farmers and forestry clients cannot rely on external causes or original private intent to stay outside Article 9(1).

C-624/10 Commission v France

Judgment · 15 December 2011 · France

A French administrative tolerance displacing the reverse charge was unlawful

The Court finds the infringement established. The scheme breached the VAT Directive and in particular Articles 168, 171, 193, 194, 204 and 214. Where the reverse charge applies the person liable is the customer, and a non established supplier that is not liable for the tax must recover its input VAT through the refund procedure rather than through a domestic registration and set-off. France was ordered to pay the costs. A reminder that the person liable for the tax and the route to recovering input VAT are fixed by the directive and are not at the disposal of national administrative practice, however convenient the simplification.

C-385/09 Nidera Handelscompagnie

Judgment · 21 October 2010 · Lithuania

Deduction denied for want of prior VAT registration

Identification under Article 214, like the notification duty in Article 213, is a formal requirement for verification purposes, not a condition constituting the right of deduction. The only formal condition under Article 178(a) is holding a compliant invoice. Where the substantive conditions are met, deduction cannot be refused merely because the person was not identified before using the goods in his taxed activity, provided he identifies himself within a reasonable period. Member States may still impose reasonable time limits and administrative penalties. Relevant to exporters and traders established in one Member State buying locally for zero-rated export or intra-Community supply, who are not obliged to register locally but must do so to recover input VAT.

C-188/09 Profaktor Kulesza, Frankowski, Jóźwiak, Orłowski

Judgment · 29 July 2010 · Poland

Reduction of input tax deduction as a penalty for not using a cash register

The Court held that the common VAT system does not preclude a temporary restriction on the amount of deductible input tax where sales record keeping obligations are breached, provided the sanction respects proportionality, which the national court must verify. The right to deduct itself must not be rendered meaningless. A 30% withholding, preserving most of the input tax, appeared neither excessive nor inadequate. Such a measure falls under Article 22(8), not Article 27(1), and is not a turnover tax caught by Article 33. Member States may enforce cash register and accounting obligations by penalties calculated as a percentage of deductible input tax, without seeking a derogation. Relevant to retail and cash businesses across Member States operating till based reporting regimes.

C-311/09 Commission v Poland

Judgment · 6 May 2010 · Poland

Flat-rate VAT on foreign coach operators without deduction

The Court upheld the action. By applying that flat-rate charge Poland failed to fulfil its obligations under Articles 73, 168 and 273 of the VAT Directive. The taxable amount must be the consideration actually received, and the right to deduct input tax incurred for the purposes of taxed transactions cannot be denied. The additional obligations a Member State may impose under Article 273 do not extend to displacing those two rules. A straightforward but firm statement that simplification cannot be bought at the price of the two structural elements of the system. Relevant to any national scheme that substitutes a lump sum or notional base for the real consideration, particularly where it applies only to non-established operators.

C-85/95 Reisdorf v Finanzamt Köln-West

Judgment · 5 December 1996 · Germany

Proof of the right to deduct, original invoice or copies

Member States may treat as an invoice not only the original but also any other document serving as an invoice which meets criteria they themselves set. They may equally decide that no other document qualifies where an original was drawn up and is held by the recipient. Separately, since Article 18 governs only exercise of the right, not later proof of it, Member States may require the original on inspection and, where the taxable person no longer holds it, may admit other cogent evidence that the transaction actually took place. The judgment separates exercise of the deduction right from its proof on subsequent audit, and leaves both largely to national rules. Relevant to construction and property projects with long invoice trails and to anyone advising on document retention and audit defence.

Related topics

Right of deduction · Origin and scope of right of deduction · Proportionality · Proof · Persons liable for payment of VAT · Tax evasion and abuse · Rules governing exercise of the right of deduction · Direct effect · Refusal of the right to deduct · Ne bis in idem