23It is precisely in the light of the context of Article 5(8) of the Sixth Directive and the purpose of that directive that the Court has held that that provision is intended to enable the Member States to facilitate transfers of undertakings or of parts of undertakings by making such transfers simpler and by preventing the resources of the recipient from being overburdened by a disproportionate charge to tax which, in any event, would ultimately be recovered through deduction of the input VAT paid (Zita Modes, paragraph 39).