De Nederlandse Belastingdienst verleent een teruggaaf van bpm als de tenaamstelling van een motorrijtuig in het kentekenregister komt te vervallen omdat het motorrijtuig buiten Nederland wordt gebracht en wordt ingeschreven in een andere lidstaat van de EU of van de EER. Voor teruggaaf dient een bewijs van de inschrijving buiten Nederland te worden overgelegd. Een tijdelijke inschrijving volstaat niet voor teruggaaf van bpm. Dat is gedaan om misbruik van de regeling te voorkomen.
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De rechtbank is van oordeel dat het niet mogelijk is om met een beroep op de bedoeling van de wetgever de wettekst uit te leggen op een manier waarop deze kennelijk welbewust niet is geformuleerd.
De Belastingdienst heeft de naheffingsaanslag ten onrechte opgelegd. De rechtbank heeft deze vernietigd.
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