Judgment_paragraph 39 · Tratave – Tratamento de Águas Residuais do Ave SA v Autoridade Tributária e Aduaneira (C-672/17)

39Given that compliance with the requirement in question in the main proceedings enables the taxable person, a supplier of goods or services, to recover all the excess VAT paid to the tax authorities in respect of unpaid debts, that requirement does not, in principle, undermine the neutrality of VAT (see, by analogy, judgment of 26 January 2012, Kraft Foods Polska, C‑588/10, EU:C:2012:40, paragraph 37).