40On the other hand, the meaning of debtor for the purposes of the second and third indents of Article 202(3) of the Customs Code is subject to conditions which rest on matters of subjective assessment, namely that the natural or legal persons participated knowingly in the unlawful introduction of goods or in acquiring or holding unlawfully introduced goods. Such factors are likely to exclude, in certain cases, treatment as a debtor (Spedition Ulustrans, paragraphs 27 and 28).
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