Judgment_paragraph 35 · Napfény-Toll Kft. v Nemzeti Adó- és Vámhivatal Fellebbviteli Igazgatósága (C-615/21)

35However, while establishing and applying those rules falls within the competence of the Member States, the Member States must exercise that competence in a manner consistent with EU law, which requires reasonable time limits to be laid down which protect both the taxable person and the authority concerned (see, by analogy, judgment of 8 September 2011, Q-Beef and Bosschaert, C‑89/10 and C‑96/10, EU:C:2011:555, paragraph 36).