20First of all, it should be observed that the first sentence of Article 5(8) of the Sixth Directive provides that Member States may, in the event of a transfer of a totality of assets or part thereof, consider that no supply of goods has taken place and that the recipient is the successor to the transferor. It follows that, where a Member State has exercised that option, the transfer of a totality of assets or part thereof is not regarded as a supply of goods for the purposes of the Sixth Directive and, accordingly, is not subject to VAT under Article 2 of that directive (see, to that effect, Case C-408/98Abbey National [2001] ECR I-1361, paragraph 30; Case C-497/01Zita Modes [2003] ECR I-14393, paragraph 29; and Case C-29/08SFK [2009] ECR I-10413, paragraph 36).