Judgment_paragraph 28 · Dragoș Constantin Târșia v Statul român and Serviciul Public Comunitar Regim Permise de Conducere si Inmatriculare a Autovehiculelor (C-69/14)

28In so far as the recovery of a tax declared incompatible with EU law is, in the present case, hindered by the existence of a final decision of a court or tribunal imposing payment of that tax, attention should be drawn to the importance, both in the legal order of the European Union and in national legal systems, of the principle of res judicata. In order to ensure both stability of the law and legal relations and the sound administration of justice, it is important that decisions of courts or tribunals which have become definitive after all rights of appeal have been exhausted or after expiry of the time-limits provided for in that connection can no longer be called into question (judgment in Impresa Pizzarotti, C‑213/13, EU:C:2014:2067, paragraph 58 and the case-law cited).