35In the judgment of 19 December 2013, BDV Hungary Trading (C‑563/12, EU:C:2013:854), cited by the referring court, the Court observed, in paragraph 40 thereof, that in circumstances where the conditions for the exemption on exportation laid down in Article 146(1)(b) of the VAT Directive, in particular, the requirement that the goods concerned leave the customs territory of the European Union, are satisfied, no liability to pay VAT arises in respect of such a supply and there no longer exists, in principle, a risk of tax evasion or loss of tax which could justify the transaction concerned being taxed.
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