C‑164/12DMC Beteiligungsgesellschaft mbH v Finanzamt Hamburg-Mitte

Domstolens egne nøkkelord

Taxation — Corporation tax — Transfer of an interest in a partnership to a capital company — Book value — Value as part of a going concern — Agreement on the prevention of double taxation — Immediate taxation of unrealised capital gains — Different treatment — Restriction on free movement of capital — Preserving the balanced allocation of powers to impose taxes between the Member States — Proportionality.

Tolker