Simona Pescaru Date: 22.01.

2021
Student Number: 12693898

European Law Major Workshop

Case number 5: Family benefits

I. Introduction

Starting with the European Coal and Steel Community (ECSC) and its Treaty signed

in 19511, the European Union have been through different types of challenges during

the years. The European Union represents a very complex mechanism in which all the

Member States must respect the implemented rules in order to have a working system.

Since the number of countries which joined the EU increased in previous years, the

total number of Member States is now 27. The EU’s main political institutions are the

European Commission, the European Parliament, the Council of Ministers and the

European Council. The European Commission represents the executive institution of

the European Union and it is responsible for the “day-to-day administration of the

EU”2.

The tasks of the European Commission can be found in Article 17(1) TEU. The

European Commission safeguards the Treaties and oversees the application of EU

Law3.

An infringement procedure is initiated mainly by the European Commission and

rarely by a Member State, the legal provisions for this act being Article 258 TFEU,

259 TFEU and 260 TFEU4. The procedure is addressed in front of the European Court

of Justice when a Member State fails to fulfil its obligations. If the investigation

1
Catherine Barnard and Steve Peers, European Union Law (New York: Oxford University Press, Second
edition, 2017), page 13.
2
Catherine Barnard and Steve Peers, European Union Law (New York: Oxford University Press, Second
edition, 2017), page 41.
3
Treaty on European Union, art.17(1).
4
Catherine Barnard and Steve Peers, European Union Law (New York: Oxford University Press, Second
edition, 2017), page 268.

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reveals that the accused Member State has truly violated the EU law then the

infringement must end immediately. The Member State concerned by this judgment

must guarantee the enforcement of the judgment and financial sanctions can be

applied. The essay will forward a legal advice for the European Commission in which

the chances for a possible success of the infringement procedure are analysed.

II. Facts of the case

The family benefits case covers the free movement of persons, workers and the free

movement of EU citizens especially. The national government in Luxembourg

decides to change the national law and the family benefits and family tax reductions

paid for children residing in other Member States become dependent on the costs of

living in that specific Member State. It is important to mention the small territory of

Luxembourg and the geographical position because these facts can be seen as

responsible in the following phenomenon: many EU citizens who reside in France,

Belgium, Germany and The Netherlands are working in Luxembourg. In

consequence, many persons that are working in Luxembourg will be affected by this

new local decision. The EU workers contribute to the social security and tax system in

the same way as a local worker and they will receive fewer benefits due to the fact

that their children reside in another Member State, most probably close-by.

Furthermore, the EU citizens that are working in Luxembourg are not exempted in

any way from their local tax system and the amount of contribution to the national

budget remains the same as for locals.

The category of persons affected by this new national law are economically active EU

citizens, more specifically workers. Implicitly, the family members of economically

active EU workers in Luxembourg (the children) may be impacted by this decision

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Simona Pescaru Date: 22.01.2021
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when it comes to their living conditions. The case is questioning the EU citizenship

itself and its fundamental status. The European workers which have their workplace

situated in Luxembourg are treated differently in comparison to national workers

because of their children residence in other EU countries. The facts of the case can

lead to an infringement of the European Law since the persons concerned are

European Citizens which work in a Member State of the European Union and they are

not equally treated in comparison to the local workers of Luxembourg.

III. Explanation of the legal context

As mentioned in the facts of the case, the legal context of the analysed case law

relates to the rights of European citizens, more specific economically active EU

citizens (workers). The right to access social benefits is at stake for the EU citizens

working in Luxembourg that have children residing in another Member State.

Result of the fact that the case law implies EU citizens, the primary applicable

legislation is Article 20 of the Treaty on the Functioning of the European Union.

Article 20 of TFEU defines the EU citizenship status and its rights. Article 20(1)

TFEU provides a definition for the European citizenship, stating that the “Citizenship

of the Union shall be additional to and not replace national citizenship”. In this case,

the persons that are nationals of a Member State should be citizens of the Union

automatically. The Court of Justice of the European Union states in the Grzelczyk case

law5 that “the Union citizenship is destined to be the fundamental status of nationals

of the Member States”6. The EU citizens working in Luxembourg shall not be

discriminated against in any way comparing to the local workers and their access to

family benefits. The children of the EU workers in Luxembourg shall be entitled for
5
CJEU, Case C-184/99, Grzelczyk, ECLI:EU:C:2001:458 (20 September 2001).
6
CJEU, Case C-184/99, Grzelczyk, ECLI:EU:C:2001:458 (20 September 2001), paragraph 31.

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Simona Pescaru Date: 22.01.2021
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the same benefits as the children of local people in Luxembourg based on Article 20

TFEU and their common European citizenship and common working country for their

parents.

Moreover, Article 45 of the TFEU provides a very appropriate legal base for the facts

of the case because it covers the rights to non-discrimination of workers (employees)

in the EU and their freedom of movement. As defined in the Trojani case law, the EU

worker definition is that “any person who pursues activities which are real and

genuine, to the exclusion of activities on such a small scale as to be regarded as purely

marginal and ancillary, must be regarded as ‘worker’…the essential feature of an

employment relationship is that for a certain period of time a person performs services

for and under the direction of another person in return for which he receives

remuneration”7. Due to the fact that the case law refers to EU persons that perform a

real and genuine labour on a regular basis, they must receive remuneration for their

services since they also pay taxes as local workers and they are subordinated to

companies located in Luxembourg, the EU citizens activating in their domain in

Luxembourg must be regarded as workers under the CJEU worker definition and its

requirements (real and genuine work, subordination and remuneration). As workers,

Article 45(2) TFEU entails the non-discrimination rights for workers. In this situation,

the EU workers can be discriminated against based on the criterium of their children

residency in other Member States of the European Union other than Luxembourg.

They shall enjoy the same social rights as the local workers do since they contribute

in the same way to the social security and tax system of Luxembourg.

7
CJEU, Case C-456/02, Trojani, ECLI:EU:C:2004:488 (7 September 2004), paragraph 15.

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Simona Pescaru Date: 22.01.2021
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In terms of secondary legislation, the Regulation 492/2011 on free movement of

workers and Directive 2004/38 (the so-called – “Citizenship directive”) are the main

legal instruments in this Case law which concerns the EU citizenship rights and the

rights of European Workers.

Regulation 492/2011 entails in Article 7(2) that an EU worker “shall enjoy the same

social and tax advantages as national workers” meaning that the worker status of

persons, inside the European Union, facilitates a non-discriminatory approach for

those which are economically active in the host state. In this case, the EU citizens

working in Luxembourg and the local workers should enjoy the same social and tax

advantages, the same family benefits and family tax reductions (social benefits).

Article 7 of Regulation 492/2011 as a whole constitutes an applicable secondary law

regarding employment and equality of treatment.

Directive 2004/38 underlines the right to equal treatment in general in Article 24(1).

In other words, an EU citizen shall be treated equally with the nationals of

Luxembourg, which is another Member State. In paragraph 2, Article 24 entails that

workers may benefit out of social assistance, while as a derogation of Article 24(1)

the Member State is not obliged to provide the same kind of assistance to unemployed

individuals and students for example8.

The Court of Justice of the European Union defined in two different case laws the

terms social assistance and social advantages. The term of “social assistance”, as

defined in Brey C-140/129, stands for “all assistance…that can be claimed by an

individual who does not have resources sufficient to meet his own basic needs and the

8
European Parliament, Council of the European Union, Citizenship Directive 2004/38, OJ L 158, 29.4.2004,
Article 24(2).
9
CJEU, Case C-140/12, Brey, ECLI:EU:C:2013:565 (19 September 2013).

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Simona Pescaru Date: 22.01.2021
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needs of his family”10. On the other hand, “social advantages”, as defined by the

CJEU in Even C-207/78)11, are “generally granted to national workers primarily

because of their objective status as workers or by virtue of the mere fact of their

residence on the national territory.”12. Since the individuals in this case affected by the

new decision of Luxembourg are workers, they shall enjoy a broader scope of

advantages in their host Member State. The family benefits and family tax reductions

which are argued in this case shall be included in the social advantages out of EU

workers are supposed to benefit since the local workers are awarded with these rights

and treated differently based on their child residency13. The relevant background of

this situation which will be addressed by the European Commission to the CJEU as an

infringement of the EU law is that the EU citizens residing in Luxembourg are

workers and they contribute to the tax system of the country in the same way as the

local persons. Without any regard to where the children of the EU workers in

Luxembourg are residing at the moment, the rights of EU workers and their protection

must be regarded as a primary thing to consider before making the tax reductions paid

for children and the family benefits different amounts dependent on the cost of living

in the Member State where the children lives.

A relevant case law other than the ones mentioned is Guido Imfeld and Nathalie

Garcet v État Belge14. The case describes the situation of a family that has loss certain

tax advantages due to their family circumstances and the income earned by mister

Imfeld in another Member State, in Germany.

10
CJEU, Case C-140/12, Brey, ECLI:EU:C:2013:565 (19 September 2013), paragraph 61.
11
ECJ, Case C-207/78, Even, ECLI:EU:C:1979:144 (31 May 1979).
12
ECJ, Case C-207/78, Even, ECLI:EU:C:1979:144 (31 May 1979), paragraph 22.
13
European Parliament, Council of the European Union, Freedom of movement for workers 492/2011, OJ L
141, 5.4.2011, Article 7(2).
14
CJEU, Case C-303/12, Guido Imfeld and Nathalie Garcet v État Belge, ECLI:EU:C:2013:822 (12 December
2013).

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Simona Pescaru Date: 22.01.2021
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IV. Legal questions and sub-questions

In terms of legal questions and sub-questions, the paper follows this following line

of questioning:

1. Is the principle of non-discrimination in the EU breached by the new decision

made by Luxembourg regarding family benefits and family tax reductions paid for

children residing in another Member State? If yes, which form of discrimination is

at stake, direct or indirect discrimination?

After establishing if Luxembourg is discriminating direct or indirect the EU workers

and their children, the legal situation and all the possibilities of outcome must be

considered:

2. Can this new measure be justified by Luxembourg as a derogation? If the

measure taken can be justified, is it also proportionate, effective and necessary?

Furthermore, the last legal question leads to a proper conclusion of the legal advice

and it gives a more general point of view for the case:

3. Altogether, is the new national rule of Luxembourg infringing the EU law and its

correct application in any manner?

These statements must be answered in order to provide a well-established conclusion

and legal advice for the European Commission.

V. Answering the legal questions and sub-questions

1. One of the most important facts which need to be dealt with is the question if the

principle of non-discrimination, one of the fundamental principles in EU internal-

market law is respected by Luxembourg in the new national law starting as from 1

January 2019 regarding the family benefits. The principle of non-discrimination as for

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Simona Pescaru Date: 22.01.2021
Student Number: 12693898

origin and nationality of the EU citizens is based in Article 18 of the Treaty on the

Functioning of the European Union and states that “any discrimination on grounds of

nationality shall be prohibited”. In this case, the EU citizens working in Luxembourg

shall enjoy the same treatment as their in-state equivalents, local workers. EU

migrants are entitled to equal treatment as locals, especially in terms of social

advantages due to their identical recognition at EU level and their same contribution

in the social security and tax system of Luxembourg.

A briefly answer to the first question will be that the principle of non-discrimination

has been infringed by Luxembourg regarding the decision made about family benefits

and family tax reductions for working parents.

Which type of discriminatory rule is at stake in this case? The national measure does

not state that EU nationals except from the people that are Luxembourg citizens are

affected by this legislation. The measure is using implicitly the dependent children of

workers from Luxembourg which reside in another Member State in order to do this

natural “selection” concerning social advantages. Not due to the citizenship the EU

workers will receive fewer benefits than local workers of Luxembourg, the measure

argues that the country of residence of their children and the costs of living of that

Member State will be a criterium. By presumption, there are fewer chances for a

person born, raised and established in Luxembourg to have their children living in

another Member State of the European Union. In this case, the measure is an

indirectly discriminatory rule due to its criterium of selection itself. This national

decision impedes the fundamental freedom of movement for persons and it is a

disadvantage for the economically active EU citizens in Luxembourg whose children

reside in other EU countries. Many EU citizens will be affected by this new decision,

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Simona Pescaru Date: 22.01.2021
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even if the measure does not directly imply fewer family benefits for EU citizens

other than locals.

2. The second legal question and its sub-questions will follow further steps in defining

the case: As an indirectly discriminatory rule, this new measure is a breach of EU law

(Article 45 TFEU and Article 7(2) Regulation 492/2011 mainly), unless it can be

justified by treaty exceptions or mandatory requirements.

In terms of treaty exceptions, Article 45 TFEU entails its limitations in Article 45(3)

TFEU: the infringement can be justified on grounds of public policy, public health

and public security. Article 45(4) TFEU is mentioning also that the provisions of the

entire Article 45 do not apply to employment in the public service. Luxembourg can

then prove in front of the Court of Justice of the European Union that the new

measure concerning family benefits has the objective of protecting public policy,

health of security. It is less likely that an argumentation based on public health,

Luxembourg may try to argue that the protection of public policy was the core of this

measure, for instance, when it comes to the preservation of the state and different

living costs in other Member States, also regarding different policies that can occur

from one EU country to another. The public security and social security nature that

the family benefits and family tax reduction have might also represent an interesting

turning point of their defending. There is also the possibility of trying to argue that the

family benefits will be more limited in order to ensure the stability and sustainability

of the benefit system in Luxembourg. Generally, an argument that is solid enough

based on treaty exceptions is difficult to reach in this case and less likely to succeed,

because the equal treatment principle shall prevail.

As for mandatory requirements, Luxembourg may be able to defend the new decision

by relying on a case law that was already judged and its subject and outcome were

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similar and relevant to the present case. This option is unlimited and dynamic and is

an exception that can be used only in case of indistinctive applicable national rules.

Moreover, even if the measure can be justified, it still needs to fulfil additional

requirements: the national rule regarding family benefits must be proportional,

effective and necessary. Luxembourg must prove that the measure is the least

restrictive option available in order to achieve their goal (proportional). It is also

important to be able to prove that the measure was effective and the result strived for

has been achieved. Lastly, the measure must be necessary in order to be seen as a

derogation. Another important additional requirement in this case is to prove that the

decision made is in conformity with the fundamental rights of the European Union.

Until proving the contrary, the measure is discriminating against EU citizens which

have the same monetary contribution to the social security and tax system of

Luxembourg. It is difficult to create a solid argumentation that is able to prove the

legitimacy of the measure and its necessity.

3. The last legal question posed represents an overall of the case and its conformity

with EU law. Undoubtedly, the facts of the case are questioning the legality of the

measure. The EU law can be very easily infringed by the measure, the workers that

are working in the same companies and contributing equally to the same tax system

will be treated differently due to their children country of residence. In terms of

legality, it is not equitable to implement such a measure which will stand between EU

citizens and their fundamental rights. EU Workers shall be treated equally in all

Member State, no matter their nationality or their children residency as long as they

are EU citizens. The discrimination between workers is not in conformity with EU

law and the fundamental principles in the EU internal-market law. Unless a

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Simona Pescaru Date: 22.01.2021
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derogation can be justifiable, the decision is affecting many EU citizens that are

economically active in a negative way, infringing their rights. It is important to

mention that a derogation cannot be misapplied in order to serve purely economic

reasons15, because economic reasons cannot justify restrictions on the European free

movement. The EU citizenship as a fundamental status of the workers shall be taken

into consideration and the EU workers shall not be discriminated in terms of benefits.

Through paying taxes, the economically active EU citizens in Luxembourg are

supposed to enjoy equal treatment in all aspects.16 Consequently, it is most likely that

the national rule infringes the EU law and is disrupting its correct application.

VI. Theoretical framework of analysis

In the past few years, many theories and public opinions have been questioning the

European immigration caused by the free movement of persons and its outcomes on

the Member States economy. Due to different living costs from one Member State to

another, a general imbalance exists in terms of minimum wage, social benefits and

social advantages. One of the reasons why EU citizens tend to find job opportunities

in a different Member State is the standard of living.

Should the Member States treat every situation and individual different based on their

private situation in order to avoid an economic burden? Such a mentality has been

developed in the new measure of Luxembourg which established that family benefits

and family tax reductions paid for children residing in another Member State shall be

dependent on the costs of living of that Member State. The fact that EU immigrants

may represent a “welfare burden” on the host Member State has triggered many
15
Catherine Barnard and Steve Peers, European Union Law (New York: Oxford University Press, Second
edition, 2017), page 403.
16
Catherine Barnard and Steve Peers, European Union Law (New York: Oxford University Press, Second
edition, 2017), page 407.

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Simona Pescaru Date: 22.01.2021
Student Number: 12693898

researchers and it is important to mention that a person is entitled to social advantages

if it is a citizen of the country or a habitual resident, not only because they are

contributing to the tax and social security system17. This theory may be seen as

doubting the fundamental status of the EU citizenship. Luxembourg may be able to

refer to the residence of the children in order to avoid providing a larger amount of

family benefits, but the working EU parents are unfairly treated in comparison to local

workers.

Bruno Peeters named the controversial relation between the free movement of persons

and the family benefits “a hard to reconcile combination” 18. The journal article

analyses the cross-border situation similar to the present case and its complexity. In

such cases, the different legislations from one Member State to another may cause

“inconsistencies”19. The refusal of Member States to collaborate with each other in

these cases creates disadvantages for the working people and self-employed.

Normally, tax payers shall benefit from the same social advantages as local workers,

but the inter-state element in such situations can be disputable. Depending on yet

unknown facts from the family benefits case discussed in the essay, such as if both

parents work in Luxembourg and travel home regularly or if only one works in

Luxembourg and the other one works and resides in another Member State with the

children. The article written by Bruno Peeters explores such possibilities and

considers specific circumstances.

17
Dorte Sindbjerg Martinsen, Gabriel Pons Rotger, “The Fiscal Impact of EU Immigration on the Tax-Financed
Welfare State: Testing the ‘welfare Burden’ Thesis.” European Union politics 18, no. 4 (December 2017): 625.
18
Bruno Peeters, “Mobility of EU Citizens and Family Taxation: A Hard to Reconcile Combination”. EC Tax
Review 23, no.3(June 2014).
19
Bruno Peeters, “Mobility of EU Citizens and Family Taxation: A Hard to Reconcile Combination”. EC Tax
Review 23, no.3(June 2014): 120.

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Simona Pescaru Date: 22.01.2021
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Another relevant journal article deals with the complexity of the family benefits when

interstate elements occur in the EU and the definition of specific terms related to this

topic20. The author mentions that one of the most disputable matters regarding family

benefits in the EU is to determine the applicable legislation and the Member State

concerned when cross-borders elements exist21. If the residing Member State of the

children has a different legislation which makes the Member State where the parents

are working responsible for the family benefits, then the children and parents may

remain without any benefit and tax reduction if Luxembourg continues the

implementation of the new measure. Generally, the economically active EU citizens

shall “be the subject to the legislation of the Member State where they work” 22. The

impact of cross-border elements may become very significant in such situations

whereas every case and family situation may be different from another. However, the

national measure taken by Luxembourg can infringe and overlap with the EU law.

Multiple times controversies occurred about this topic. It may sound unlawful that a

child residing in a Member State with lower living costs will not receive the same

child allowance as a child residing in Luxembourg even if their parents work in the

same place. The contribution to the national tax system of the parents is equal but

their family tax reduction will be different due to the residency of their children. A

relevant Journal Article debates the indexation of family benefits in the EU and its

impact on free movement of workers23. The authors determine specific amounts of

20
Strban, Grega. “Family Benefits in the EU: Is it Still Possible to Coordinate Them?” Maastricht Journal of
European and Comparative Law 23, no.5 (October 2016): 775–795. 
21
Strban, Grega. “Family Benefits in the EU: Is it Still Possible to Coordinate Them?” Maastricht Journal of
European and Comparative Law 23, no.5 (October 2016): 786.
22
Strban, Grega. “Family Benefits in the EU: Is it Still Possible to Coordinate Them?” Maastricht Journal of
European and Comparative Law 23, no.5 (October 2016): 787.
23
Michael Blauberger, Anita Heindlmaier and Carina Kobler. “Free movement of workers under challenge: the
indexation of family benefits.” Comparative European Politics 18 (July 2020), 925-943.

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Simona Pescaru Date: 22.01.2021
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money which can become savings for the state when they adopt such behaviour and it

is unlikely for the Member State to save a large amount of money in this scenario 24.

Political reasoning might be behind such new national measures that are depriving EU

workers from their regular amount of family benefits. The indexation of family

benefits is nowadays an issue and a grey area of the European law25.

VII. Conclusion

Given these points, the debate whether such a national measure is ethic and legal

remains open. The legal advice that I forward to the European Commission is that the

infringement procedure can be launched and there are big chances of success. The

outcome of this case may be argued in both directions, but after considering the EU

internal-market law principle of non-discrimination and the specific EU legislation

involved, the European Commission may prove the present infringement. The EU

citizenship represents a fundamental status which has its benefits regarding equal

treatment. The case involves economically active EU citizens, workers, which shall

have equal rights regarding social advantages in the host Member States. The new

national rule is incompatible with the free movement of workers in the European

Union. The European fundamental rights of persons must be considered by the

Member States before taking new decisions which affect migrants. The cross-border

element of the case gives the possibility for the European Commission to intervene

and employ the right to free movement of the involved EU citizens working in

Luxembourg. The EU workers contribute to the local tax system in the same manner

24
Michael Blauberger, Anita Heindlmaier and Carina Kobler. “Free movement of workers under challenge: the
indexation of family benefits.” Comparative European Politics 18 (July 2020), 928.
25
Michael Blauberger, Anita Heindlmaier and Carina Kobler. “Free movement of workers under challenge: the
indexation of family benefits.” Comparative European Politics 18 (July 2020), 940.

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Simona Pescaru Date: 22.01.2021
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as locals, therefore they are not a burden to the state. The controversial situation is

questioning the European Integration process at a large scale and tends to discriminate

among European citizens. The existent infringement triggers the EU migrants with

families abroad who benefit out of child allowances or family tax reduction. The host

state prefers to calculate the costs of living in the state of residency of the children and

is not considering the contribution that EU migrants have in their territory. The

indexation faced by the EU citizens working in Luxembourg is unjustifiable in such a

European context. It is true that the living costs may differ from one country to

another, but also the economic situation of the family may be different.

The argumentation used is favourable to the European migrants in Luxembourg, that

are indirectly discriminated due to the national measure. The European law shall

prevail and the European Commission shall ensure and oversee the application of EU

law26.

Bibliography

Barnard, Catherine and Steve Peers, European Union Law. New York: Oxford

26
Treaty on European Union, art.17(1).

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Simona Pescaru Date: 22.01.2021
Student Number: 12693898

University Press, Second edition, 2017.

Blauberger, Michael, Anita Heindlmaier and Carina Kobler. “Free movement of

workers under challenge: the indexation of family benefits.” Comparative European

Politics 18 (July 2020), 925-943.

https://doi-org.proxy.uba.uva.nl:2443/10.1057/s41295-020-00216-3

CJEU, Case C-140/12, Pensionsversicherungsanstalt v Peter Brey,

ECLI:EU:C:2013:565 (19 September 2013).

CJEU, Case C-184/99, Rudy Grzelczyk v Centre public d'aide sociale d'Ottignies-

Louvain-la-Neuve, ECLI:EU:C:2001:458 (20 September 2001).

CJEU, Case C-456/02, Michel Trojani v Centre public d'aide sociale de Bruxelles

(CPAS), ECLI:EU:C:2004:488 (7 September 2004).

European Parliament, Council of the European Union, Directive 2004/38/EC of the

European Parliament and of the Council of 29 April 2004 on the right of citizens of

the Union and their family members to move and reside freely within the territory of

the Member States amending Regulation (EEC) No 1612/68 and repealing Directives

64/221/EEC, 68/360/EEC, 72/194/EEC, 73/148/EEC, 75/34/EEC, 75/35/EEC,

90/364/EEC, 90/365/EEC and 93/96/EEC (Text with EEA relevance), OJ L 158,

29.4.2004, CELEX number: 32004L0038.

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Simona Pescaru Date: 22.01.2021
Student Number: 12693898

Martinsen Dorte Sindbjerg and Pons Rotger. “The Fiscal Impact of EU Immigration

on the Tax-Financed Welfare State: Testing the ‘welfare Burden’ Thesis.” European

Union Politics 18, no. 4 (December 2017): 620–639.

https://doi-org.proxy.uba.uva.nl:2443/10.1177%2F1465116517717340

Peeters, Bruno. “Mobility of EU Citizens and Family Taxation: A Hard to Reconcile

Combination.” EC tax review 23, no. 3 (June 2014): 118–120.

https://lib.uva.nl/permalink/31UKB_UAM1_INST/1hfh82p/cdi_kluwer_law_ECTA2014012

Strban, Grega. “Family Benefits in the EU: Is it Still Possible to Coordinate Them?”

Maastricht Journal of European and Comparative Law 23, no.5 (October 2016) 775–

795. 

https://doi.org/10.1177/1023263X1602300503

Treaty on European Union

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18