Opinion of Advocate General Rantos delivered on 15 September 2022.#Fenix International Limited v Commissioners for Her Majesty's Revenue and Customs.#Request for a preliminary ruling from the First-tier Tribunal (Tax Chamber).#Reference for a preliminary ruling – Implementing power of the Council of the European Union – Article 291(2) TFEU – Common system of value added tax (VAT) – Directive 2006/112/EC – Articles 28 and 397 – Taxable person, acting in his or her own name but on behalf of another person – Provider of services by electronic means – Implementing Regulation (EU) No 282/2011 – Article 9a – Presumption