Judgment_paragraph 18 · Beteiligungsgesellschaft Larentia + Minerva mbH & Co. KG v Finanzamt Nordenham and Finanzamt Hamburg-Mitte v Marenave Schiffahrts AG (C-108/14, C-109/14)

18In that regard, it should be noted, in the first place, that a holding company whose sole purpose is to acquire shares in other undertakings and which does not involve itself directly or indirectly in the management of those undertakings, without prejudice to its rights as a shareholder, does not have either the status of taxable person, within the meaning of Article 4 of the Sixth Directive, or the right to deduct tax under Article 17 of that directive (see, inter alia, judgments in Cibo Participations, C‑16/00, EU:C:2001:495, paragraph 18, and Portugal Telecom, C‑496/11, EU:C:2012:557, paragraph 31).