55The interpretation of the concept of ‘conversion’ given in Article 52 of this judgment is, moreover, in line with the objective of the VAT Directive, in particular that of taxation of a transaction that seeks to increase the value of the property at issue. For new buildings, as the Advocate General observed in points 71 and 72 of his Opinion, that added value is the result of construction work that leads to a substantial modification of what physically exists as a result of the transition from immovable property without a building, or even undeveloped land, to a habitable building. For old buildings, that added value arises when a substantial transformation has taken place, such that the old building in question may be regarded as a new building.
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