regional and local government authorities and other bodies
governed by public law shall not be considered taxable
persons in respect of the activities or transactions in
which they engage as public authorities, even where they
collect dues, fees, contributions or payments in connection
with these activities or transactions .
However, when they engage in such activities or
transactions, they shall be considered taxable persons in
respect of these activities or transactions where treatment
as non-taxable persons would lead to significant distortions
of competition .
In any case, these bodies shall be considered taxable
persons in relation to the activities listed in Annex D,
provided they are not carried out on such a small scale as
to be negligible .
Member States may consider activities of these bodies which
are exempt under Article 13 or 28 as activities which they
engage in as public authorities ."