31First of all, according to the Court’s settled case-law, the principle of the protection of legal certainty is aimed at ensuring foreseeability of situations and legal relations and requires, inter alia, that the tax position of the taxable person, having regard to his rights and obligations vis-à-vis the tax or customs authorities, not to be open to challenge indefinitely (see, to that effect, inter alia, judgments in Alstom Power Hydro, C‑472/08, EU:C:2010:32, paragraph 16, and Elsacom, C‑294/11, EU:C:2012:382, paragraph 29).
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