Until 26 June 2003 European VAT was based on several principles: service providers were persons who contractually rendered services to their customers; the taxable base was the amount that the supplier and customer agreed actually on (and was subsequently invoiced); persons were considered taxable persons in so far as they were engaged in economic activities, i.e. making supplies for consideration to third parties and "exploitation of tangible or intangible property for the purpose of obtaining income therefrom on a continuing basis" was exploitation with a certain durability. All those principles were thrown overboard when the ECJ delivered its judgment in the MKG case relating to true factoring.