51In fact, whereas, through the mechanism of the deduction of tax laid down by Articles 17 to 20 of the Sixth Directive, VAT taxes only the final consumer and is completely neutral as regards the taxable persons involved in the production and distribution process prior to the stage of final taxation, regardless of the number of transactions involved (see, to that effect, Case C-317/94 Elida Gibbs [1996] ECR I-5339, paragraphs 19, 22 and 23; Case C-427/98 Commission v Germany [2002] ECR I-8315, paragraph 29; and Banca Popolare di Cremona, paragraph 32), that is not the case with a tax such as the HIPA.
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