In its decision of 12 January 2006, the European Court of Justice (ECJ) declared that for company tax purposes, services performed by a grandparent company for a grandchild company generally benefit the intermediary company and are therefore to be attributed to that company. If this decision is followed, it means that in future, contributions from grandparent companies will generally be subject to taxation. There are, however, good reasons for not following this decision of the ECJ: first, because this decision is at variance with the opinion of the Advocate general and with the ECJ´s own earlier rulings, and second, because at present, company tax is only still imposed in 8 Member States (and thus not or no longer imposed in 17) and efforts are currently in progress at European level to abolish it completely in the medium term. It is therefore doubtful whether the Ministry of Finance will follow this decision. It would be desirable if the Ministry were to decide against doing so; however, no official statement has been issued as yet.