The Cross-border Merger Directive of 26 October 2005 sets forth rules to permit and facilitate the merger of limited liability compan-ies situated in different Member States of the European Union and the European Economic Area. It is completed by Council Directive 90/435/ EEC of 23 July 1990, which provides for a common system of taxation applicable to mergers between parent companies and their subsidiaries located in different Member States, which has been replaced by Council Directive 2009/133/EC of 19 October 2009 which did not change the content (in this book referred to as the ‘Merger Tax Directive’). With respect to procedural.