Judgment_paragraph 52 · Hecta Viticol SRL v Agenţia Naţională de Administrare Fiscală (ANAF) – Direcţia Generală de Soluţionare a Contestaţiilor and Others (C-184/19)

52As a preliminary point, it should be borne in mind that the principles of legal certainty and the protection of legitimate expectations require, first, that rules of law must be clear and precise and, second, that their application must be foreseeable by those subject to them (see, to that effect, judgment of 11 September 2019, Călin, C‑676/17, EU:C:2019:700, paragraph 50 and the case-law cited).