Judgment_paragraph 39 · Euro Tyre BV – Sucursal em Portugal v Autoridade Tributária e Aduaneira (C-21/16)

39In 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 judgment of 20 October 2016, Plöckl, C‑24/15, EU:C:2016:791, paragraph 44 and the case-law cited).