In the Latvian case of A Redlihs v Valsts ieņēmumu dienests (CJEU Case C-263/11) the owner of a forest had not registered for VAT. Many of the trees in his forest were felled by a storm and he sold some of the timber without accounting for VAT on the sales. The tax authority imposed a penalty for failure to register and he appealed contending that his sales of timber should not be treated as an ‘economic activity’. The case was referred to the CJEU for a ruling on the interpretation of Article 9(1) of Directive 2006/112/EC. The CJEU held that Article 9(1) ‘must be interpreted as meaning that supplies of timber made by a natural person for the purpose of alleviating the consequences of a case of force majeure come within the scope of the exploitation of tangible property which must be regarded as an...