24It is thus apparent from the case-law of the Court relating to Article 11 of Directive 69/335, and in particular from the judgments in FECSA and ACESA (EU:C:1998:508) and in Commission v Belgium (EU:C:2004:450), that, in accordance with the objectives of that directive, the prohibition of the taxation of transactions for the raising of capital also applies to transactions which are not expressly covered by that prohibition, where such taxation is tantamount to taxing a transaction forming an integral part of an overall transaction with regard to the raising of capital. That interpretation is capable of being applied to Article 5(2) of Directive 2008/7 which reproduces, in identical terms, Article 11 of Directive 69/335.
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