Judgment_paragraph 31 · IM Gestão de Ativos (IMGA) – Sociedade Gestora de Organismos de Investimento Coletivo SA v Autoridade Tributária e Aduaneira (C-656/21)

31Since services relating to the marketing of shares in common funds, such as those at issue in the main proceedings, are closely linked to the operations relating to the issuing and making available on the market of shares, within the meaning of Article 5(2)(a) of Directive 2008/7, they must be regarded as forming an integral part of an overall transaction with regard to the raising of capital.