Opinion of Advocate General Bot in the case Pieńkowski.
The provisions of Articles 146(1)(b), 147, 131 and 273 of Council Directive 2006/112/EC, together with the principle of fiscal neutrality, should be interpreted as precluding national legislation which excludes application of the exemption to a taxable person who does not satisfy the condition relating to attainment of a minimum turnover during the preceding tax year and who has not concluded an agreement with a person authorised to refund tax to travellers.
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