50The finding made in paragraph 48 of this judgment applies a fortiori in the context of insolvency or winding-up proceedings, in which the certainty that the debt is definitively irrecoverable can, in principle, be established only after a lengthy period. Such a period is, in any event, such as to inflict on traders subject to that legislation, when they are confronted with non-payment of an invoice, a cash-flow disadvantage compared to their competitors in other Member States, which would clearly undermine the objective of fiscal harmonisation pursued by Directive 2006/112 (see, by analogy, judgment of 23 November 2017, Di Maura, C‑246/16, EU:C:2017:887, paragraph 28).
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