Official Journal of the European Union

C series

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C/2025/3022

10.6.2025

Judgment of the Court (Tenth Chamber) of 3 April 2025 (request for a preliminary ruling from the Administrativen sad Veliko Tarnovo – Bulgaria) – ‘Cityland’ EOOD v Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna praktika’ – Veliko Tarnovo

(Case C-164/24,

(1)

Cityland)

(Reference for a preliminary ruling - Common system of value added tax - Directive 2006/112/EC - Persistent failure to comply with tax obligations - Removal of the taxable person from the value added tax (VAT) identification register - Principle of proportionality)

(C/2025/3022)

Language of the case: Bulgarian

Referring court

Parties to the main proceedings

Applicant:

‘Cityland’ EOOD

Defendant: Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna praktika’ – Veliko Tarnovo

Operative part of the judgment

The first subparagraph of Article 213(1) and Article 273 of Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax, as amended by Council Directive (EU) 2017/2455 of 5 December 2017, and the principles of legal certainty and of proportionality

must be interpreted as precluding national legislation which, as interpreted by the tax authorities and the national courts, provides for the possibility for the competent tax authority to remove a taxable person from the value added tax (VAT) register on the ground of a failure to comply with VAT obligations on that taxable person’s part, without that tax authority analysing the nature of the infringements committed and the conduct of the taxable person at issue.

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(1) OJ C C/2024/3160.

ELI: http://data.europa.eu/eli/C/2025/3022/oj

ISSN 1977-091X (electronic edition)

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