19At the request of the Helsingin hallinto-oikeus, the Finnish Ministry of Finance issued an opinion in which it stated, first, that Directive 69/335 does not preclude Member States from charging a duty on the transfer of property in securities and, second, that an exchange of shares involves a transfer which is subject to such a duty. It added that the scope of Article 12(1)(c) of Directive 69/335 is, according to the judgments in Case C-42/96 Immobiliare SIF [1997] ECR I-7089 and Case C-236/97 Codan [1998] ECR I-8679, strictly defined.
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