33The interpretation of the no-supply rule set out in paragraph 28 above is, moreover, supported by the fact that that rule, laid down in the first paragraph of Article 19 of the VAT Directive, cannot be regarded as a derogation from a tax obligation justifying a restrictive interpretation. It is applicable only where the VAT charged on the transaction, where appropriate, would have been deductible and it also implies that the recipient is to be regarded as the successor to the transferor in the pursuit of the activity (see, to that effect, judgment of 19 December 2018, Mailat, C‑17/18, EU:C:2018:1038, paragraph 29; see also, to that effect and by analogy, judgment of 27 November 2003, Zita Modes, C‑497/01, EU:C:2003:644, paragraph 43).