Opinion of Advocate General Hogan delivered on 25 February 2021.#UBS Real Estate Kapitalanlagegesellschaft mbH v Agenzia delle Entrate.#Requests for a preliminary ruling from the Corte suprema di cassazione.#Reference for a preliminary ruling – Free movement of capital – Closed-ended mutual investment funds – Open-ended mutual investment funds – Investments in real estate – Mortgage registration tax and land registry fees – Tax advantage granted only to closed-ended real estate investment funds – Difference in treatment – Comparability of situations – Objective criteria of differentiation.#Joined Cases C-478/19 and C-479/19.