65Lastly, as regards the objectives pursued by Article 273 of the VAT Directive, the obligation on the Member States to take all measures necessary to ensure collection of all VAT and to counter evasion, referred to in paragraph 60 above, may, in certain circumstances, require a Member State to impose penalties on non-taxable persons who take part in decision-making within a taxable legal person, otherwise the effectiveness of such measures would be undermined.
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