Judgment_paragraph 48 · Cartrans Spedition Srl v Direcţia Generală Regională a Finanţelor Publice Ploieşti - Administraţia Judeţeană a Finanţelor Publice Prahova and Direcţia Regională a Finanţelor Publice Bucureşti - Administraţia Fiscală pentru Contribuabili Mijlocii (C-495/17)

48In those circumstances, in order for a supply of transport services to be exempt from VAT on the basis of Article 146(1)(e) of the VAT Directive and, if that supply of services is carried out by an intermediary acting in the name and on behalf of another person, on the basis of Article 153 of that directive, it is in principle necessary that goods in question have in fact been exported, namely that the goods have been delivered outside the European Union, the reality of which must be established to the satisfaction of the competent tax authorities. Such a requirement, which thus relates to the substantive conditions necessary for the granting of an exemption, cannot, therefore, be regarded as a purely formal obligation within the meaning of the case-law cited in paragraph 38 of the present judgment.