Opinion of the Advocate General

Mr Advocate General Lenz delivered his Opinion on 15 February 1989. He proposed that the Court should rule as follows:

‘Article 11 of Directive 69/335/EEC must be interpreted as meaning that, since 1 January 1972 at the latest, the Member States may not charge “capital companies” within the meaning of Article 3 of that directive, in respect of the transactions set out in Article 11 thereof, tax of any kind other than capital duty or the duties referred to in Article 12.’

1 Original language: German.