27It points out that in paragraph 35 of its judgment in Case C-221/88 Busseni [1990] ECR I-495 the Court held that the principle of the protection of legitimate expectations does not prevent new rules from applying to the future effects of situations which arose under the earlier rules. It also considers that, from the point of view of Community law, the legislation at issue in the main proceedings is not to be regarded as having retroactive effect. The Italian legislature should, of course, take care when reducing the period for initiating proceedings to ensure that the taxpayers concerned are not brusquely deprived of the right to recover taxes contrary to Community law. It follows that, when determining the manner in which that period is to be reduced, the legislature should provide for a reasonable transitional period so that the taxpayers concerned can, provided that they display the necessary diligence, safeguard the possibility of recovering debts owing to them which arose when the tax in question was unlawfully levied.
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