The questions raised by the present case essentially ask, first, whether the French tax on the market
value of
immovable property owned in France by a company established in a Member State is also applicable where the company is established in an overseas country or territory (OCT), being in the present case the British Virgin Islands, and, second, whether the joint and several liability for payment of that tax on the part of any legal person interposed between the party or parties liable to the tax and the
immovable properties located in France constitutes a restriction of free movement of capital.