Judgment_paragraph 95 · Wilo Salmson France SAS v Agenţia Naţională de Administrare Fiscală - Direcţia Generală Regională a Finanţelor Publice Bucureşti and Agenţia Naţională de Administrare Fiscală - Direcţia Generală Regională a Finanţelor Publice Bucureşti - Administraţia Fiscală pentru Contribuabili Nerezidenţi (C-80/20)

95In that regard, the Court has stated that it is compatible with EU law to lay down reasonable time limits for bringing proceedings 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 (judgments of 14 June 2017, Compass Contract Services, C‑38/16, EU:C:2017:454, paragraph 42 and the case-law cited, and of 2 July 2020, Terracult, C‑835/18, EU:C:2020:520, paragraph 32 and the case-law cited).