Judgment_paragraph 75 · MC v Direktor na Direktsia „Obzhalvane i danachno-osiguritelna praktika“ Veliko Tarnovo pri Tsentralno upravlenie na Natsionalnata agentsia za prihodite (C-1/21)

75Accordingly, exercise of the Member States’ power to designate a joint and several debtor other than the person liable for payment of the tax in order to ensure efficient collection of that tax must be justified by the factual and/or legal relationship between the two persons concerned in the light of the principles of legal certainty and of proportionality. In particular, it is for Member States to specify the particular circumstances in which a person such as the recipient of a taxable supply is to be held jointly and severally liable for payment of the tax owed by the other party to the contract even though that person has paid that tax by paying the transaction price (judgment of 20 May 2021, ALTI, C‑4/20, EU:C:2021:397, paragraph 34).