22As a derogation from the fundamental principle which underlies the common system of VAT, according to which VAT applies to each transaction by way of production or distribution (see, in particular, Case C-62/93 BP Soupergaz [1995] ECR I-1883, paragraph 16; Joined Cases C-354/03, C-355/03 and C-484/03 Optieen and Others [2006] ECR I-483, paragraph 54; and Joined Cases 0439/04 and 0440/04 Kittel and Recolta Recycling [2006] ECR I-6161, paragraph 49), that exemption is based on the transitional VAT regime applicable to intra-Community trade, under which the taxation of trade between the Member States is based on the principle that tax revenues should accrue to the Member State in which the final consumption takes place (see Case C-184/05 Twoh International [2007] ECR I-7897, paragraph 22).
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