different involving different tests. With this in mind, Vanistendael contends it is conceivable to have more than one concept of abuse. 6.2 After the VAT cases: should the abuse concept be codified? Turning to the question of whether or not the abuse concept as elaborated in the VAT cases should be characterised as a uniform national concept borrowed from EU law, Vanistendael focuses on the fact that the PS decision has made this obsolete. He argues against a possible codification at Union level, much unlike the Opinion of Advocate General Maduro in Halifax, which concerned balancing the prohibition of abuse against the principles of legal certainty. Instead, he argues it would be more appropriate for the Court to further develop different concepts of abuse and have one which is specific to national situations, applied in accordance with secondary EU tax legislation. To do so would give more leeway to national courts in such situations. The author endorses the opinion of the Advocate General over that put forward by Vanistendael. Part Service is indeed proof that the Court has shown an inclination to allow national courts to apply national law in the area of VAT, however this is insufficient in supporting the argument that more than one concept of abuse exists. 6.4 A chasm appearing in the area of VAT? Whatever the arguments against multiple concepts of abuse existing, it would appear that in the case of VAT at least, the development in Part Service highlights the need for appropriate criteria to prevent further differentiation. In the context of civil law jurisdictions, the Halifax criteria is ultimately imperfect. If we compare the substance of the referred questions in both cases, there is a core element common to both. This further supports the argument that only one concept of abuse exists. As VAT is an object of common policy and interpreted in such a way that does not exactly match other areas of taxation, it >