20Like the tax charged on inheritances, which consist in the transfer to one or more persons of assets left by a deceased person and likewise fall under that heading of Annex I to the directive (see, inter alia, Case C-256/06 Jäger [2008] ECR I-123, paragraph 25; Eckelkamp and Others, paragraph 39; Arens-Sikken, paragraph 30; Block, paragraph 20; and Case C-35/08 Busley and Cibrian Fernandez [2009] ECR I-9807, paragraph 18), the tax treatment of gifts, whether they are gifts of money, immovable property or movable property, therefore comes under the Treaty provisions on the movement of capital, except where their constituent elements are confined within a single Member State (see, to that effect, Persche, paragraph 27).
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