2.The Government of the Kingdom of the Netherlands maintains that the contribution levied pursuant to the General Law on Old-Age cannot be treated as equivalent to a tax.Although, like a tax, it is collected periodically and according to a register of assessments, the contribution is distinguished by the fact that to its payment there is an actual (differentiated) corresponding benefit, namely a right to a pension from the fund to which the payment was made. This distinction was established by the judgment of the Court of Justice in Case 32/67 (Van Leeuwen, Rec. 1968, p. 63).The contribution paid under general old-age insurance does not fall to the Treasury but goes to a special fund managed by an agency specially set up for this purpose and does not come under the budget of the State. The general old-age insurance is financed by an allocation of charges, which in principle implies self-finance. The only analogies, purely technical or practical, with a tax are the fact that the contribution is to a certain extent calculated proportionally on the contributor's income and that the revenue authorities are involved in its collection. The judgment in the Humblet case cannot be relied on in this case as it relates to procedure which is indisputably fiscal.
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