Is the 5% fine for failure to reverse charge VAT constitutional?

The Council of State considered that the question deserved to be put to the Constitutional Council.

The purchaser, recipient or customer identified for VAT purposes in France, liable for VAT in the context of reverse charge and who has not collected VAT on his turnover return, shall incur a correction in the amount of tax for which he is liable.

Source Benoit Cassar

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