On 13 March 2025 the Court of Justice of the European Union (CJEU) delivered its judgment in Direcţia Generală Regională a Finanţelor Publice Galaţi – Administraţia Judeţeană a Finanţelor Publice Vrancea, Direcţia Generală de Administrare a Marilor Contribuabili v Greentech SA C‑640/23. The court was asked to interpret Articles 2, 19, 168 and 203 of the VAT Directive, together with the principles of the neutrality of VAT, legal certainty and the protection of legitimate expectations, in the context of additional VAT liabilities imposed on Greentech SA by the Romanian tax authority. The additional VAT liabilities arose when the tax authority reclassified the sale of equipment by Greenfiber to Greentech. The transaction had originally been treated as a supply of goods subject to VAT (VAT charge by Greenfiber with input credit for Greentech) but was later reclassified as a transaction subject to transfer-of-business relief and outside the scope of VAT. After an audit of Greenfiber it was determined that the original VAT charge was correct, but owing to the passage of time it was not possible under the legislation to correct the invoice and for Greentech to obtain a refund of the VAT paid to Greenfiber.