Opinion of Advocate General Gulmann delivered on 12 May 1992

1 Original language: Danish.

2 OJ, English Special Edition 1969 (I), p. 232.

3 The directive concerns both turnover tax and excise but Article 6(2), in fine, specifically excludes tax remission on export in the case of excise.

4 The Court interpreted the directive in, inter alia, its judgment in Case C-278/82 REWE II [1984] ECR 721.

5 I consider some form of consolidation of the text of the directive would be desirable in the interest not only of greater legal certainty for citizens but also of effective implementation of the directive in the Member Sutes.

6 OJ, English Special Edition 1972 (II), p. 565.

7 OJ 1985 L 366, p. 28.

8 OJ 1985 L 183, p. 24.

9 On the harmonization of the laws of the Member States relating to turnover taxes — Common system of value added tax: uniform basis of assessment, OJ 1977 L 145, p. 1, hereinafter the Sixth Council Directive.

10 [1988] ECR 4517.

11 Nothing in the case indicates that this situation is due to the fact that the other Member States impose stricter conditions for ordinary invoices than does Spain.