In Ǻkerberg Fransson, the issue concerned whether the principle of ne bis in idem provided for in Article 50 Charter, applied to proceedings brought against Mr Ǻkerberg Fransson on charges of serious tax offences, including providing false information in relation to VAT. Several intervening Member States, together with the Commission, argued that the Charter was not applicable since the legislation which formed the basis for the proceedings was not implementing EU law. The Court disagreed: it found that the tax penalties and the criminal proceedings to which Mr Ǻkerberg Fransson was subjected were in part connected to his obligations to declare VAT. The Court then found that it followed from Directive 2006/112,103 as well as from the principle of loyal cooperation, that Member States have an obligation to take ‘all legislative and administrative measures’ to ensure collection of VAT due on their territory. Furthermore, since part of the VAT revenue is destined to the EU’s own resources, a lacuna in collection of the tax would also determine a reduction in the revenues of the EU. Since Article 325 TFEU obliges Member States to counter illegal activities affecting the financial interests of the EU, the tax penalties at issue also constituted implementation of that provision of the Treaty. For these reasons, and even though the proceedings also related to the collection of income tax, which is not harmonized at EU level, the Court found that the tax penalties and the criminal proceedings constituted ‘implementation’ of EU law and therefore fell within the scope of application of the Charter.