Judgment_paragraph 39 · Frenetikexito – Unipessoal Lda v Autoridade Tributária e Aduaneira (C-581/19)

39To that end, as the Advocate General observed in points 22 to 33 of her Opinion, it is necessary to identify the characteristic elements of the transaction in question (judgments of 29 March 2007, Aktiebolaget NN, C‑111/05, EU:C:2007:195, paragraph 22, and of 18 January 2018, Stadion Amsterdam, C‑463/16, EU:C:2018:22, paragraph 30), from the perspective of the average consumer (judgment of 19 July 2012, Deutsche Bank, C‑44/11, EU:C:2012:484, paragraph 21 and the case-law cited). The body of evidence relied on for this purpose comprises various elements, the first of which, being of an intellectual nature and of decisive importance, seek to establish whether or not the elements of the operation in question are indivisible (judgment of 28 February 2019, Sequeira Mesquita, C‑278/18, EU:C:2019:160, paragraph 30) and its economic purpose, whether or not this is unique (judgment of 2 July 2020, Blackrock Investment Management (UK), C‑231/19, EU:C:2020:513, paragraph 34), and the second of which, being of a substantive nature and not of decisive importance (see, to that effect, judgment of 25 February 1999, PPC, C‑349/96, EU:C:1999:93, paragraph 31), support, where appropriate, the analysis of the first elements, such as separate access (judgment of 17 January 2013, BGŻ Leasing, C‑224/11, EU:C:2013:15, point 43) or joint access (judgment of 8 December 2016, Stock '94, C‑208/15, EU:C:2016:936, point 33) to the services in question or the existence of a single invoice (order of 19 January 2012, Purple Parking and Airparks Services, C‑117/11, not published, EU:C:2012:29, paragraph 34 and the case-law cited) or a separate invoice (judgment of 18 January 2018, Stadion Amsterdam, C‑463/16, EU:C:2018:22, paragraph 27).