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This three-part article discusses the compatibility of exit tax legislation applicable to corporate taxpayers in France, Germany, Italy, the Netherlands, Portugal, Spain and the United Kingdom with the EU freedom of establishment, especially in the light of the ECJ’s landmark National Grid decision. Part 1 scrutinizes whether a company transferring its tax residence or effecting an outbound cross-border conversion has access to Articles 49 and 54 TFEU under the laws of the Member State. It also addresses whether these laws restrict Article 49, and, if so, whether the restriction can be justified and is appropriate to ensure the attainment of its objective. Parts 2 and 3, each to be published in subsequent Intertax issues, review whether the legislation is proportional, address which other transactions the ECJ’s exit tax principles apply to, and provide conclusions and recommendations.

Live Saccharomyces cerevisiae yeast strains are widely used as feed additives for dairy cow s. Although, perfectly safe and applied in several food processes, the potential contamination of milk by the strain and more generally its possible influence on the microbial profile of milk could be questioned, this concerns particularly traditi onal cheeses made with raw milk. In an attempt to address these questions, two experiments were performed: A trial in an experimental farm , where two groups of cows, one receiving yeast supplementation and the other one being an unsupplemented control, were compared and a field trial where herds received alternatively yeast-supplemented and control diets. In both cases, viable counts of different microbial groups, including yeasts and molds in general and S. cerevisiae in particular were analysed in tank milk and results from suppleme nted groups or periods were compared with control ones. No v iable S. cerevisiae were detected in any of the samples analysed. Moreover, no n oticeable differences in the microbial profiles were observed. This applies also to the evolution of the microbial composition during an experimental cheese processing trial. These data sug gest that live yeast additive distributed to dairy cows does not influence milk microbial composition and cheese-making abilities.

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