Court of Justice of the European Union

Judgment of 21 May 2015

Case C-657/13

In the Judgment in question, rendered in the context of a reference for a preliminary ruling, the Court of Justice of the European Union determined that Article 49 of the TFEU is to be interpreted as not precluding a tax legislation of a Member State, such as that in the case of a transfer of assets from a company located within the territory of that Member State to a permanent establishment of that company located in the territory of another Member State, provides for the disclosure of unrealised capital gains pertaining to those assets which have been generated within the territory of that first Member State, the taxation of such capital gains and the collection in 10 instalments of the tax relating to those gains.