27First of all, it should be observed that Article 25(1) of the Sixth Directive confers on the Member States the right to apply a common flat-rate scheme to farmers where the application to them of the normal VAT scheme, or the simplified scheme provided for in Article 24 of that directive, would give rise to difficulties. That special scheme, which is applicable to certain farmers, is therefore an exception to the general scheme provided for in the Sixth Directive. That it is an exception is, as the Advocate General stated in point 31 of his Opinion, confirmed by the fact that, under Article 25(9) and (10), the Member States may exclude from that scheme certain categories of farmer and that any flat-rate farmer is entitled to opt for application of the normal scheme or the simplified scheme. Like the other special schemes provided for in Articles 24 and 26 of the Sixth Directive, the scheme under Article 25 must therefore be applied only to the extent necessary to achieve its objective (see, in respect of the application of the scheme provided for in Article 26 of the Sixth Directive, Madgett and Baldwin, cited above, paragraph 34). Moreover, it is settled case-law that any exception to a general rule is to be interpreted strictly (Case C-83/99 Commission v Spain [2001] ECR I-445, paragraph 19).
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