Opinion statement ECJ-TF 3/2014 of the CFE on the decision of the European Court of Justice of 23 January 2014 in DMC (Case-164/12), concerning taxation of unrealized gains upon a reorganization within the UE

This is an Opinion Statement prepared by the CFE ECJ Task Force1 on Case C-164/12, DMC. After illustrating the facts of the DMC case and the preliminary questions, this document will focus on selected critical points from this case by pointing out some differences between it and its most immediate relevant precedent, National Grid Indus, which has been the subject of a previous Opinion Statement by the CFE.4