44In the first place, the principle of fiscal neutrality cannot be invoked for the purposes of an exemption from VAT by a taxable person who has intentionally participated in tax evasion which has jeopardised the operation of the common system of VAT (see, to that effect, judgments of 7 December 2010, R., C‑285/09, EU:C:2010:742, paragraph 54, and of 27 September 2012, VSTR, C‑587/10, EU:C:2012:592, paragraph 46).
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