19As regards the latter principle, the Court has held that it is compatible with Community law to lay down reasonable time-limits for bringing proceedings in the interests of legal certainty which protects both the taxpayer and the administration concerned (Case 33/76 Rewe v Landwirtschafskammer Saarland, cited above, paragraph 5, and Case 45/76 Comet v Produktschap voor Siergewassen, cited above, paragraphs 17 and 18; Denkavit Italiana, cited above, paragraph 23; see also Case C-261/95 Palmisani v INPS [1997] ECR I-4025, paragraph 28, and Case C-90/94 Haahr Petroleum v Åbenrå Havn and Others [1997] ECR I-4085, paragraph 48). Such time-limits are not liable to render virtually impossible or excessively difficult the exercise of rights conferred by Community law. In that regard, a time-limit of three years under national law, reckoned from the date of the contested payment, appears reasonable (see Edis and SPAC, cited above, paragraphs 35 and 19 respectively).
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