European Court of Justice Issues Advocate General Opinion on Bulgarian Criminal Prosecution of VAT Fraud

April 28, 2026, 5:00 AM UTC

The European Court of Justice (ECJ) April 23 issued an Advocate General opinion for Case No. C-321/25, on Bulgarian criminal prosecution of VAT fraud. The taxpayers, individuals, had criminal proceedings initiated against them for VAT fraud as part of organized crime. There were judge and court changes over the years. Upon request for a preliminary ruling, the Advocate General opined that: 1) the Treaty on the Functioning of the European Union (TFEU) and the Convention on the Protection of the European Communities’ Financial Interests don’t preclude national law specifying an absolute limitation period for prosecuting crimes against the EU’s financial ...

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