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Recitals 101 to 107 of that decision, relating to the existence of a selective advantage, state: ‘(101) The measure is also clearly selective. In the first place, it only applies to holders of financial cooperative shares and not to persons holding investment products issued by competing undertakings. Thus financial players which offered conservative bond or money market funds or capital-guaranteed mutual funds could not offer their clients a similar guarantee. The Belgian State argues that individual shares of financial cooperatives are in essence similar to deposits. However, a number of the elements which the Belgian State invoked refer to cooperatives in general not to financial cooperatives. In addition, the description of financial cooperative shares offered by the Belgian State does not contain references to relevant information, such as the risks of investing in those instruments, which are not characteristic of deposits. (102) The selective nature of the measure can also be seen when the treatment of financial cooperatives is compared to other recognised cooperatives that are non-financial. The Belgian State relied on [the judgment of 8 September 2011, Paint Graphos and Others (C‑78/08 to C‑80/08, EU:C:2011:550),] to plead in favour of special treatment for individual shareholders of financial cooperatives. … (103) The Commission considers that the argument of the Belgian State cannot succeed because the nature of the advantage conferred by the measure is qualitatively different from that which was examined by the Court in Paint Graphos [and Others (C‑78/08 to C‑80/08)]. The measure put in place by Belgium involves the creation of a positive benefit and not relief from a fiscal burden or from an obligation to pay a charge. As such, the standard three-part analysis which the Union courts have endorsed when examining whether a fiscal advantage or exemption from a levy is selective cannot be applied to the measure. (104) In any event, even if the Paint Graphos [and Others (C‑78/08 to C‑80/08)] analysis could be applied to the measure, the latter’s specific features are such that its selective nature would remain. (105) First the Commission observes that Paint Graphos [and Others (C‑78/08 to C‑80/08)] refers to all producers’ and workers’ cooperatives, not to a relatively small subsector such as financial cooperatives. If, as Belgium claims, there should be special treatment for “genuine” cooperatives, that special treatment should apply to all recognised cooperatives. The limited focus of the measure on financial cooperatives only is therefore sufficient in itself to establish the selective nature of the measure. (106) Second, the Commission observes that in the view of the Belgian State, financial cooperatives seemed to deserve additional privileges as of 10 October 2008. The Commission observes that prior to that date recognised cooperatives got a form of favourable treatment as a result of their special status in the form of a withholding tax exemption. The Commission does not take a view in the present Decision on whether that tax advantage is proportionate but it believes that there was no reason to introduce suddenly on 10 October 2008 additional compensation for, or protection of, companies which have the status of financial cooperatives. (107) Finally, even if the Commission were to enter into a Paint Graphos and Others (C‑78/08 to C‑80/08, EU:C:2011:550)] analysis as proposed by Belgium, it believes that there is no justification for providing a 100% guarantee to individual shareholders of ARCO …, whose entities were limited liability companies. Because of the nature of such companies as determined by Belgium’s general rules on company law, individual shareholders of ARCO should have been aware that they could lose their entire capital in case of a liquidation. Moreover, protecting 100% of all capital subscribed by the individual shareholders of financial cooperatives is not a proportionate measure … as those shareholders would be shielded from any risk, which would create an undue advantage for the undertakings of which they are shareholders.’