Judgment of the Court (Eighth Chamber) of 18 September 2019.#AQ and DN v Ministre de l'Action et des Comptes publics.#Requests for a preliminary ruling from the Conseil d'État.#References for a preliminary ruling — Direct taxation — Directive 90/434/EEC — Directive 2009/133/EC — Article 8 — Capital gains relating to exchange of securities transactions — Transfer of securities received at the time of the exchange — Capital gain on which tax has been deferred — Taxation of the shareholders — Taxation on the basis of different bases of assessment and rate rules — Reductions of the basis of assessment taking into account the period for which securities have been held.#Joined Cases C-662/18 and C-672/18.