Judgment_paragraph 45 · Ampafrance SA v Directeur des services fiscaux de Maine-et-Loire and Sanofi Synthelabo v Directeur des services fiscaux du Val-de-Marne (C-177/99, C-181/99)

45Ampafrance further states that, in accordance with Case C-63/96 Finanzamt Bergisch Gladbach v Skripalle [1997] ECR I-2847, paragraph 30, the Council could not authorise the introduction of national derogations whose purpose was to attain objectives other than those restrictively listed in Article 27 of the Sixth Directive. In seeking authorisation from the Council to derogate from the rules of the Sixth Directive, the French authorities were not seeking to combat the risks of tax evasion and avoidance, but to put in place a mechanism which would obviate the requirement to check whether certain expenditure was incurred for business purposes or not.