Comments on ECJ 314/22: Member state CAN limit the time for applying for VAT bad debt relief BUT it cannot be too burdensome for the taxpayer

A Bulgarian taxpayer provided construction services and claimed overpayment of VAT plus interest in 2020, due to non-payment by the purchasers.
The tax authority denied the correction, citing the expiry of the limitation period and unjustified overpayment.
The court clarified that there can be a time limit for applying for bad debt relief, but it should not make exercising this right impossible or excessively difficult.
The time limit starts from when the taxpayer was able to assert the right to a reduction.
The taxpayer does not have to correct the invoice or inform the debtor to take advantage of bad debt relief, and is entitled to interest if a tax refund is not paid within a reasonable time.