29Thus, the Court has held that, where an issue of securities has no point until those securities find investors, a tax on the initial acquisition of a newly issued security is in reality levied on the very issue of that security as it forms an integral part of an overall transaction with regard to the raising of capital. The aim of maintaining the practical effect of Article 5(2)(a) of Directive 2008/7 implies, therefore, that ‘issue’, for the purposes of that provision, includes the first acquisition of securities immediately consequent upon their issue (see, by analogy, judgment of 15 July 2004, Commission v Belgium, C‑415/02, EU:C:2004:450, paragraphs 32 and 33).
Source: EUR-Lex, © European Union, 1998-2026. Reuse authorised under Decision 2011/833/EU.