Judgment_paragraph 28 · Direktor na Direktsia ‘Obzhalvane i upravlenie na izpalnenieto’ — grad Burgas pri Tsentralno upravlenie na Natsionalnata agentsia za prihodite v Orfey Balgaria EOOD (C-549/11)

28Thus, in order for VAT to be chargeable before the supply of goods or services is made, all the relevant information concerning the chargeable event, namely the future supply of goods or services, must already be known and therefore, in particular, the goods or services must be precisely identified at the time the payment on account is made (BUPA Hospitals and Goldsborough Developments, paragraph 48, and Case C-520/10 Lebara [2012] ECR, paragraph 26). Therefore, payments on account of supplies of goods or services that have not yet been clearly identified cannot be subject to VAT (BUPA Hospitals and Goldsborough Developments, paragraph 50, and Case C-270/09 MacDonald Resorts [2010] ECR I-13179, paragraph 31).