European Union – Freedom of establishment. The Court of Justice of the European Union held that the obligation laid down in art 45 of Council Directive (EEC) 85/611, under which an undertakings for collective investment in transferable securities which marketed its units within the territory of a member state other than that in which it was situated was required to make payments to unit holders in the member state of marketing, had to be interpreted as not including the delivery to unit holders of certificates providing evidence of title to units which were registered in their name in the register of unit holders kept by the issuer.