Judgment_paragraph 60 · J.B.G.T. Miljoen and Others v Staatssecretaris van Financiën (C-10/14, C-14/14, C-17/14)

60The expenses identified by the referring court in its reference for a preliminary ruling in Case C‑17/14 do not have such a link. As regards, first, the deduction of the dividend included in the purchase price of the shares, it is apparent from the documents before the Court that the purpose of that deduction is to establish the actual purchase price of the shares. That deduction does not, therefore, concern expenses which are directly linked to the actual payment of the dividends arising from those shares. Secondly, the financing costs also mentioned by the referring court concern ownership of the shares per se, and therefore they are also not directly linked to the actual payment of the dividends arising from those shares.