Opinion Statement ECJ-TF 3/2014 on the case C-164/12, concerning taxation of unrealized gains upon a reorganisation within the EU

This is an Opinion Statement prepared by the CFE ECJ Task Force 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.