54Such a measure, in so far as it leads to the chargeable event for the taxation of that capital gain being deferred until the year in which the event putting an end to the deferral of taxation occurs, namely the transfer of securities received in exchange, ensures, as the Advocate General observed in points 59 and 60 of his Opinion, that the exchange of securities in itself does not give rise to any taxation of that capital gain. That measure therefore respects the principle of fiscal neutrality as set out Article 8(1) of the Merger Directive.
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