32The detailed procedural rules governing actions for safeguarding a taxpayer’s rights under EU law must thus be no less favourable than those governing similar domestic actions (principle of equivalence) and must not be framed in such a way as to render impossible in practice or excessively difficult the exercise of rights conferred by EU law (principle of effectiveness) (see, inter alia, Joined Cases C-317/08 to C-320/08 Alassini and Others [2010] ECR I-2213, paragraph 48 and the case law cited, and Agrokonsulting-04, paragraph 36).
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