Judgment_paragraph 32 · SC Terracult SRL v Direcţia Generală Regională a Finanţelor Publice Timişoara –Administraţia Judeţeană a Finanţelor Publice Arad – Serviciul Inspecţie Fiscală Persoane Juridice 5 and ANAF Direcţia Generală Regională a Finanţelor Publice Timişoara Serviciul de Soluţionare a Contestaţiilor (C-835/18)

32As regards the principle of effectiveness, which requires that a national procedural provision must not make the exercise of the rights conferred on individuals by EU law practically impossible or excessively difficult, it is clear from the Court’s case-law that the possibility of exercising the right to a refund of VAT, without any temporal limit, would be contrary to the principle of legal certainty, which requires the tax position of the taxable person, having regard to his rights and obligations vis-à-vis the tax authorities, not to be open to challenge indefinitely. The Court has also stated that it is compatible with EU law to lay down reasonable time limits for bringing proceedings, if they are not to be out of time, in the interests of legal certainty, which protects both the taxpayer and the authorities concerned. Such periods are not by their nature liable to make it virtually impossible or excessively difficult to exercise the rights conferred by EU law, even if the expiry of those periods necessarily entails the dismissal, in whole or in part, of the action brought (see, to that effect, judgment of 14 February 2019, Nestrade, C‑562/17, EU:C:2019:115, paragraphs 41 and 42 and the case-law cited).