31However, it should be noted that Article 205 of the VAT Directive, read in the light of the principle of proportionality, requires that the presumption on which Article 51bis(4) of the VAT Code relies, in order to consider a taxable person jointly and severally liable for payment of the VAT due with the person who is liable for that VAT, may be rebuttable, in the sense that it is not practically impossible or excessively difficult for that taxable person to rebut that presumption with evidence to the contrary.
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