29Moreover, if it were possible to make an application for the refund of excess VAT without any temporal limit, that would be contrary to the principle of legal certainty, which requires the tax position of the taxable person, having regard to his rights and obligations vis-à-vis the tax authorities, not to be open to challenge indefinitely (see Case C-472/08 Alstom Power Hydro [2010] ECR I-623, paragraph 16 and the case-law cited).
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