24Thirdly, in order to be exempt from VAT under Article 13A(l)(g) to (i) of the Sixth Directive, the Foundation's services as intermediary must be closely linked to the childcare services. The Commission and the Netherlands Government deny that such a link exists, relying in particular on Case C-287/00 Commission v Germany [2002] ECR I-5811, in which exemption under Article 13A(l)(i) of the Sixth Directive for research activities carried out for consideration by public institutions of higher education was disallowed. The Court held, at paragraph 49 of that judgment, that the supply of such services was not closely related to university education, after having stated, at paragraph 48, inter alia that ‘although the undertaking of such projects may be regarded as of great assistance to university education, it is not essential to attain its objective’.
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