52That principle, as enshrined in Article 49 of the Charter, must be observed by the Member States when they implement EU law, in accordance with Article 51(1) of the Charter, which is the case where, in the context of their obligations under Article 325 TFEU, they provide for the application of criminal penalties for infringements relating to VAT. The obligation to ensure the effective collection of the Union’s resources cannot therefore run counter to that principle (see, by analogy, judgment of 29 March 2012, Belvedere Costruzioni, C‑500/10, EU:C:2012:186, paragraph 23).
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