The purpose of this newsflash is to draw your attention to a judgment handed down by the Court of Justice of the European Union (the "CJEU") on 9 October 2014 (CJEU C-299/13 Gielen). In answer to the Belgian Constitutional Court's request for a preliminary ruling of 16 May 2013, the CJEU ruled that the tax on the conversion of bearer shares is contrary to Directive 2008/7/EC of 12 February 2008 concerning indirect taxes on the raising of capital (the "Directive").