As a result of this, while the CJEU had the occasion to declare in C - 228 / 06 Soysal and Savatli that Article 41 (1) precluded the introduction of a VISA requirement for Turkish nationals willing to
provide services in Germany if the said requirement was introduced after the signature of the
Additional protocol, in Demirkan the CJEU introduced — for the first time in EU law - the
distinction between active and passive freedom to receive services.