24As regards, in particular, the rules pertaining to the taxation of acquisitions of new means of transport, it can be seen from recital 11 in the preamble to Directive 2006/112, which reiterates the content of the 11th recital in the preamble to Directive 91/680, that those rules, in addition to covering the allocation of authority to tax, aim to prevent distortions of competition between the Member States liable to result from the application of differing rates of tax. If there were no transitional arrangements, the marketing of new means of transport would tend to be confined to Member States having a low VAT rate, to the detriment of the other Member States and their taxation revenue. As the Advocate General pointed out at point 34 of her Opinion, the European Union legislature has, by Article 2(1)(b)(ii) of Directive 2006/112, made the acquisition of new means of transport not only by taxable persons and non-taxable legal persons, but also by private persons, subject to tax, inter alia because of the high value and easy transportability of those goods.
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