C-646/15Trustees of the P Panayi Accumulation & Maintenance Settlements v Commissioners for Her Majesty's Revenue and Customs

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Reference for a preliminary ruling — Direct taxation — Freedom of establishment — Freedom to provide services — Free movement of capital — Trust — Trustees — Other legal persons — Meaning — Tax on gains in value of assets held in trust by reason of the trustees’ place of residence for tax purposes being transferred to another Member State– Determination of the amount of tax due at the time of that transfer — Tax payable immediately — Justification — Proportionality.

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