OPINION OF ADVOCATE GENERAL

   KOKOTT

   delivered on 15 October 2020 ( [1]1 )

   Case C-596/19 P

   European Commission

   v

   Hungary

   (Appeal - State aid - Article 107(1) TFEU - Turnover-based
   advertisement tax - Advantage and selectivity - Standard of review in
   establishing the reference system - Consistency of the reference
   system - Advantage in respect of a progressive rate - Standard of
   review in the case of an exception to the reference system - Advantage
   arising from the possibility of using losses in the first tax year -
   Difference in treatment - Justifications for differences in treatment -
   Transitional regime as aid)

   I. Introduction

   1.

   This appeal gives the Court an opportunity once again ( [2]2 ) to
   review a recently introduced tax law in the light of the rules on State
   aid. Following the international trend, Hungary based a direct business
   tax on turnover rather than profit and opted for a progressive rate
   structure. It was intended, in a similar way to the EU digital services
   tax proposed by the Commission, ( [3]3 ) to cover and tax primarily
   undertakings with high turnovers (that is to say, large undertakings).
   For the first tax year, as a transitional measure, the law provided for
   the apportionment of any losses from the previous year.

   2.

   Because the average tax rate increases with the volume of turnover,
   there is a degree of relief or redistribution of the tax burden in
   favour of `smaller' undertakings. Even though the planned digital
   services tax at EU level and the advertisement tax in Hungary are
   similar in this respect, the Commission considers the Hungarian tax to
   constitute State aid for smaller undertakings, which are `taxed at too
   low a level'. In addition, the possibility of using losses in the year
   in which the tax was introduced favours undertakings which were
   loss-making in the previous year compared with undertakings which were
   not loss-making. The Commission therefore requested Hungary to recover
   the connected aid and, by subsequent assessment, to levy the tax at a
   rate of 5.3%. Hungary thereupon abolished the advertisement tax with
   retroactive effect but, like Poland in a parallel case, ( [4]4 )
   considers the Commission's action to be an infringement of its fiscal
   autonomy.

   3.

   The present appeal proceedings thus not only raise the question whether
   a progressive business tax can actually constitute a selective
   advantage for the purposes of Article 107(1) TFEU. The question also
   arises whether the rules on State aid are the proper instrument for
   reviewing national tax legislation in this depth and, as happened here,
   for blocking it for years. A related question is whether or not the
   standard of review for general tax laws should be different in the
   rules on State aid than for individual grants.

   4.

   It should also be borne in mind that an intensive check on
   discrimination is already made through the fundamental freedoms. In
   this context, the Court has already held two similar turnover-based
   direct business taxes in Hungary to be compatible with the fundamental
   freedoms in their redistributive purpose. ( [5]5 ) It is true that the
   comparison groups are different, as the Commission rightly pointed out
   at the hearing. In tax law, the fundamental freedoms prohibit foreign
   undertakings being placed at a disadvantage, while the prohibition of
   State aid prevents the favouring of `certain undertakings'. However,
   both prohibitions of discrimination serve the completion of the
   internal market. If a measure is compatible with the prohibition of
   discrimination under the fundamental freedoms, it would probably not,
   as a rule, be aid which is incompatible with the internal market.

   5.

   The General Court ( [6]6 ) did not consider the general Hungarian tax
   law to be selective advantage for other undertakings, either in the
   progressive rate or in the possibility of using losses. This is
   contested by the Commission in its appeal and the Court of Justice must
   now examine whether it constitutes aid.

   II. Legal framework

   6.

   The legal framework is provided by Article 107 et seq. TFEU. The
   procedure regarding unlawful aid is regulated in Chapter III of
   Regulation (EU) 2015/1589 laying down detailed rules for the
   application of Article 108 TFEU ( [7]7 ) (`Regulation 2015/1589').

   III. Background to the dispute

   7.

   On 11 June 2014, Hungary enacted Law No XXII of 2014 on advertisement
   tax (`the Law on advertisement tax'). That law entered into force on
   15 August 2014 and introduced a new special tax, applied progressively
   by bands, on turnover derived from the broadcasting or publication of
   advertisements in Hungary (`the advertisement tax'). That tax was
   applied in addition to existing business taxes, in particular
   corporation tax. During the examination of the Law on advertisement tax
   carried out by the Commission as part of the monitoring of State aid,
   the Hungarian authorities stated that the purpose of that tax was to
   promote the principle of public burden sharing.

   8.

   According to the Law on advertisement tax, whoever broadcasts or
   publishes advertisements is subject to the advertisement tax. Those who
   make advertisements public (newspapers, audiovisual media, billposters)
   are therefore taxable persons, but not advertisers or advertising
   agencies who are intermediaries between advertisers and broadcasters or
   publishers. The taxable amount to which the tax is applied is the net
   turnover for the financial year generated by the broadcasting or
   publication of advertisements. The territorial scope of the tax is
   Hungary.

   9.

   The scale of progressive rates was defined as follows:

   -

   0% for the part of the taxable amount below 0.5 billion Hungarian
   forint (HUF) (approximately EUR 1562000);

   -

   1% for the part of the taxable amount between HUF 0.5 billion and HUF 5
   billion (approximately EUR 15620000);

   -

   10% for the part of the taxable amount between HUF 5 billion and HUF 10
   billion (approximately EUR 31240000);

   -

   20% for the part of the taxable amount between HUF 10 billion and
   HUF 15 billion (approximately EUR 47000000);

   -

   30% for the part of the taxable amount between HUF 15 billion and
   HUF 20 billion (approximately EUR 62500000);

   -

   40% for the part of the taxable amount above HUF 20 billion
   (approximately EUR 94000000). (That rate was increased to 50% from
   1 January 2015).

   10.

   Taxable persons whose pre-tax profits for the financial year 2013 were
   zero or negative could deduct from their 2014 taxable amount 50% of the
   losses carried forward from the earlier financial years (hereinafter
   referred to as `the possibility of using losses').

   11.

   By decision of 12 March 2015, the Commission initiated the formal
   investigation procedure for State aid, provided for in Article 108(2)
   TFEU, in relation to the Law on advertisement tax, taking the view that
   the progressive nature of the tax rate and the possibility of using
   losses gave rise to State aid. In that decision, the Commission
   considered that the progressive tax rate differentiated between
   undertakings with high advertisement revenues (large undertakings) and
   undertakings with low advertisement revenues (small undertakings). A
   selective advantage was thereby granted to the latter based on their
   size. The Commission was also of the view that the possibility of using
   losses for undertakings that were not profit-making in 2013 granted a
   selective advantage constituting State aid.

   12.

   In the context of that same decision, the Commission issued a
   suspension injunction in respect of the measure at issue. Subsequently,
   Hungary amended the advertisement tax by Law No LXII of 2015, enacted
   on 4 June 2015. The scale of six progressive rates from 0 to 50% was
   replaced by the following scale comprising two rates of taxation:

   -

   0% for the part of the taxable amount below HUF 100 million
   (approximately EUR 312000);

   -

   5.3% for the part of the taxable amount above HUF 100 million.

   13.

   The Commission closed the formal investigation procedure by Decision
   (EU) 2017/329 of 4 November 2016 on the measure SA.39235 (2015/C) (ex
   2015/NN) implemented by Hungary on the taxation of advertisement
   turnover ( [8]8 ) (`the negative decision').

   14.

   In Article 1 of the contested decision, the Commission concluded that
   the tax system composed of progressive tax rates and provisions
   prescribing a possibility of using losses for undertakings that were
   not profit-making in 2013, established by Law No XXII of 2014 on
   advertisement tax, including the version of that law as amended on
   4 June 2015, constituted State aid. This had been unlawfully put into
   effect by Hungary in breach of Article 108(3) TFEU. It was also
   incompatible with the internal market in the light of Article 107 TFEU.
   In Article 4 of the negative decision, the Commission ordered Hungary
   to recover from the beneficiaries the aid declared incompatible with
   the internal market.

   15.

   In that regard, the Hungarian authorities were to recover from the
   undertakings with advertisement turnover in the period from the entry
   into force of the advertisement tax in 2014 to the date of either its
   abolishment or replacement by a system which would be fully in line
   with State aid rules, the difference between: the amount of tax (1)
   that those undertakings should have paid under the application of a
   reference system in line with State aid rules (with a single tax rate
   of 5.3% unless another value was chosen by the Hungarian authorities,
   without the deduction of any losses carried forward) and the amount of
   tax (2) that the undertakings were liable to pay or had already paid.
   Consequently, if the difference between amount of tax (1) and amount of
   tax (2) was positive, the amount of aid had to be recovered, including
   interest as of the date the tax was due.

   16.

   The Commission stated, however, that there would be no need for
   recovery if Hungary abolished the tax system at issue with retroactive
   effect from the date of its entry into force in 2014. For the future,
   for example from 2017, Hungary would then be able to introduce a tax
   system which was not progressive and did not differentiate between
   economic operators subject to the tax.

   17.

   In essence, the Commission justified characterising the system at issue
   as State aid in the following manner:

   18.

   Since the Law on advertisement tax was enacted, Hungary waived
   resources it would have had to collect from undertakings with a lower
   level of turnover (smaller undertakings) if they had been subject to
   the same level of tax as undertakings with a higher turnover (larger
   undertakings).

   19.

   The Commission noted that, just like positive benefits, measures which
   mitigated the charges normally borne by undertakings provided an
   advantage. In the present case, being taxed at a substantially lower
   tax rate mitigated the charges that undertakings with a low turnover
   must bear as compared to undertakings with a high turnover and
   therefore provided an advantage to the benefit of smaller undertakings
   over larger undertakings.

   20.

   The possibility of using losses under the Law on advertisement tax for
   undertakings that were not profit-making in 2013 also constituted an
   advantage. It reduced their tax burden compared to undertakings that
   could not benefit from that deduction.

   21.

   In examining selectivity, the Commission stated, first, that the
   reference system was that of a special tax on turnover derived from the
   provision of advertising services. But, according to the Commission,
   the progressive rate structure of the advertisement turnover tax could
   not form part of that reference system. In order for the reference
   system itself to be free from State aid, the Commission stated that it
   had to fulfil two conditions. Advertisement turnovers must be subject
   to the same (single) tax rate (1) and there must be no element that
   would provide a selective advantage to certain undertakings (2).

   22.

   To that extent, the Commission considered, next, that the progressive
   structure of the taxation, in that it entailed not only marginal tax
   rates but also average tax rates, which differed between undertakings,
   constituted a derogation from the reference system composed of a
   single-rate advertisement tax applied to all economic operators
   broadcasting or publishing advertisements in Hungary.

   23.

   In addition, the Commission considered that the possibility of using
   losses only for undertakings that were not profit-making in 2013 also
   constituted a derogation from the reference system, namely the rule
   that operators are to be taxed on the basis of their turnover from
   advertisements. According to the Commission, since the advertisement
   tax relates to turnover, costs were not to be deductible from the
   taxable amount, contrary to what might be the case for profit-based
   taxes. The measure introduced an arbitrary distinction between two
   groups of undertakings that are in a comparable legal and factual
   situation, namely undertakings that had losses carried forward, and
   were not profit-making in 2013 and undertakings that were profit-making
   in 2013. The deduction of losses already existing at the time of the
   enactment of the Law on advertisement tax entailed selectivity because
   the allowance of that deduction favoured certain undertakings with
   substantial losses carried forward.

   24.

   As regards the 2015 amended version of the advertisement tax, the
   Commission stated that that version was based on the same principles
   and features as those chosen for the 2014 advertisement tax.
   Accordingly, the Commission concluded that the Law on advertisement tax
   as amended in 2015 featured the same elements that the Commission
   regarded as entailing State aid in respect of the 2014 system.

   25.

   On 16 January 2017, Hungary brought an action against the negative
   decision. The application for suspension of operation of the negative
   decision made by Hungary on the same date was dismissed by order of
   23 March 2017. ( [9]9 )

   26.

   On 16 May 2017, Hungary enacted Law No XLVII of 2017 amending the Law
   on advertisement tax. In essence, that law repealed the advertisement
   tax with retroactive effect.

   27.

   By decision of 30 May 2017, the President of the Ninth Chamber of the
   Court granted the Republic of Poland leave to intervene in support of
   Hungary.

   28.

   In the action brought by Hungary, the General Court annulled the
   negative decision by the Commission by the judgment under appeal of
   27 June 2019.

   IV. Procedure before the Court

   29.

   On 6 August 2019, the Commission lodged the present appeal against the
   judgment of the General Court. The Commission claims that the Court
   should:

   -

   set aside the judgment under appeal;

   -

   reject the second and third pleas raised by Hungary against the
   contested decisions and order it to pay the costs of the proceedings;

   -

   in the alternative, refer the case back to the General Court for a
   ruling on the pleas that have not yet been examined.

   30.

   Hungary, supported by the Republic of Poland, contends that the Court
   should:

   -

   dismiss the appeal as unfounded;

   -

   order the Commission to pay the costs of the proceedings.

   31.

   Hungary, Poland and the Commission submitted written observations on
   the appeal before the Court and presented oral arguments on 1 September
   2020.

   V. The grounds of appeal

   32.

   The Commission relies on two grounds of appeal. By the first ground of
   appeal, the Commission alleges that the General Court misapplied
   Article 107(1) TFEU in so far as it rejected a selective advantage
   arising from the Hungarian advertisement tax for lower-turnover
   undertakings. According to the second ground of appeal, the General
   Court misinterpreted Article 107(1) TFEU because, contrary to the view
   taken by the General Court, the possibility of using losses constitutes
   a selective advantage.

   A. First ground of appeal: incorrect interpretation of
   Article 107(1)TFEU

   33.

   By its first ground of appeal, the Commission alleges that the General
   Court erred in law in interpreting Article 107(1) TFEU. In essence, it
   complains that the General Court wrongly rejected a selective advantage
   and thus aid. As grounds, it argues in three parts that the General
   Court chose an incorrect reference framework (see 1.a), examined the
   comparability of the undertakings in the light of a non-fiscal
   objective (see 2.a) and, in examining selectivity, took into
   consideration an objective that was not necessarily connected with the
   advertisement tax (see 2.b).

   34.

   The Court of Justice has consistently held - as was also asserted by
   the General Court - that classification as `State aid' within the
   meaning of Article 107(1) TFEU requires that, first, there must be
   intervention by the State or through State resources. Second, the
   intervention must be liable to affect trade between Member States.
   Third, it must confer a selective advantage on the recipient. Fourth,
   it must distort or threaten to distort competition. ( [10]10 ) In this
   instance it is necessary only to review the General Court's legal
   opinion on the criterion of the selective advantage.

   35.

   According to the normal standard of review, the decisive factor is
   whether, in accordance with the criteria laid down by the national tax
   system, the conditions governing the tax advantage have been selected
   in a non-discriminatory manner. ( [11]11 ) To answer that question, it
   is necessary to begin by identifying the ordinary or `normal' tax
   system applicable in the Member State concerned (the `reference
   framework'). It is in relation to that ordinary or `normal' tax regime
   that it is necessary, secondly, to assess whether the advantage granted
   by the tax measure in question is an unjustified exception and
   therefore selective. ( [12]12 )

   1.   Existence of a selective advantage or incorrect choice of
   reference framework (first part of the first ground of appeal)

   36.

   The Commission complains in particular that, in reviewing whether a
   selective advantage existed, the General Court chose the wrong
   reference framework. While the Commission assumed a turnover-based tax
   with a single (proportional) rate (evidently at a level of 5.3%), the
   General Court erroneously had regard to the progressive rate chosen by
   the Hungarian legislature.

   (a)   Selective advantage arising from a general tax law: the approach
   to examination in creating a reference framework

   37.

   Because Article 107(1) TFEU does not contain any of the constituent
   elements of a reference framework and its review consistently gives
   rise to significant difficulties - I refer to the concerns now being
   raised by several Advocates General ( [13]13 ) - it must be examined in
   some depth.

   38.

   According to settled case-law of the Court, measures which, whatever
   their form, are likely directly or indirectly to favour certain
   undertakings, or which fall to be regarded as an economic advantage
   that the recipient undertaking would not have obtained under normal
   market conditions, are regarded as State aid. ( [14]14 )

   39.

   This case-law has been applied to tax law. A tax measure which,
   although not involving the transfer of State resources, places the
   recipients in a financial position more favourable than that of other
   taxpayers can also fall under Article 107(1) TFEU. ( [15]15 ) Thus,
   measures which mitigate the charges that are normally included in the
   budget of an undertaking and which therefore, without being subsidies
   in the strict meaning of the word, are similar in character and have
   the same effect are considered to constitute aid. ( [16]16 )

   40.

   This case-law was developed against the background of fiscal exceptions
   that exempted or relieved an individual undertaking from the tax burden
   actually applicable. ( [17]17 ) Because in the present case all
   undertakings `profit' from the allowance (up to HUF 0.5 billion or, in
   the amended version, HUF 100 million) and all undertakings also
   `profit' from the reduced rates of 1% to 30% for the portion of annual
   turnover between HUF 0.5 billion and HUF 20 billion, this cannot be the
   selective advantage. At most, the different average rate resulting from
   the progressive rate structure might constitute a selective advantage
   favouring taxable persons with lower turnover.

   (1) Principle: determination of `normal' taxation by the Commission or
   the Member State?

   41.

   In essence, the first ground of appeal relied on by the Commission
   raises the question of competence as to who determines the tax burden
   that is normally to be borne by an undertaking, such that non-taxation
   of others would be to their advantage. In the Commission's view,
   `normal' taxation is a turnover-based income tax with a proportional
   rate (at an unknown level or at a level of 5.3%). In the view of the
   Hungarian legislature, `normal' taxation is a turnover-based income tax
   with a progressive rate from 0% to just below 5.3% in the amended
   version. The different average rates resulting from the progressive
   scale are the inevitable consequence and thus constitute normal
   taxation. Hungary relies on its fiscal sovereignty in this regard.

   42.

   The Court's case-law also repeatedly affirms and takes into
   consideration the fiscal autonomy of Member States. For example, only
   recently, in the Grand Chamber, the Court has again ruled that the
   Member States are free, given the current state of harmonisation of EU
   tax law, to establish the system of taxation that they deem the most
   appropriate, and consequently the application of progressive taxation
   falls within the discretion of each Member State. ( [18]18 ) In that
   context, in the view of the Grand Chamber, `contrary to what is
   maintained by the Commission, progressive taxation may be based on
   turnover, since, on the one hand, the amount of turnover constitutes a
   criterion of differentiation that is neutral and, on the other,
   turnover constitutes a relevant indicator of a taxable person's ability
   to pay.' ( [19]19 )

   43.

   The principles laid down in these rulings, which were delivered in
   connection with the fundamental freedoms, apply equally to the rules on
   State aid. In this field too, the Court has ruled that, in the absence
   of European Union rules governing the matter, it falls within the tax
   competence of the Member States to designate bases of assessment and to
   spread the tax burden across the various factors of production and
   economic sectors. ( [20]20 ) Therefore, in principle, only an exception
   to this autonomously designed tax system can be assessed on the basis
   of the rules on State aid, not the creation of the tax system itself.

   44.

   This is acknowledged as a matter of principle by the Commission in
   paragraph 156 of its Notice on the notion of State aid as referred to
   in Article 107(1) of the Treaty on the Functioning of the European
   Union, ( [21]21 ) where it states that `Member States are free to
   decide on the economic policy which they consider most appropriate [in
   accordance with Union law] and, in particular, to spread the tax burden
   as they see fit across the various factors of production ...'.

   45.

   Furthermore, I am not aware of any provision of EU law that prescribes
   a specific structure for the national taxes of the Member States,
   except for harmonised taxes. It is not therefore possible to infer
   `normal' taxation from EU law. The basis can only ever be the decision
   by the national legislature in question as to what it deems to be
   normal taxation. In the present case this is an income tax for
   advertising undertakings which is progressive in nature and the basis
   of assessment of which is turnover.

   46.

   The national legislature is thus able to determine above all the object
   of taxation, the basis of assessment and the rate structure. Hungary
   availed itself of that power in this instance by establishing a
   turnover-based income tax for advertising undertakings with a
   progressive average rate from 0% to just below 5.3% (which stems, in
   the amended version, from the allowance and a proportional rate). This
   is not precluded, in principle, by the rules on State aid.

   (2) Exception: review of consistency by the Court in the Gibraltar
   judgment

   47.

   Nor does anything to the contrary follow from the Court's ruling in the
   Gibraltar judgment, which is repeatedly cited by the Commission. In
   that ruling, the Court did examine Gibraltar's system of corporate
   taxation on the basis of the rules on State aid and accepted the
   existence of aid. However, it did not substitute its own view of
   general normal taxation for that of the Member State.

   48.

   The Court certainly did not find in that case that the rules on State
   aid prescribe a certain form of taxation. It `merely' reviewed the
   internal logic of the law at issue. Under the proposed tax reform at
   that time, uniform profit-based income taxation of all companies
   established in Gibraltar was to be introduced. ( [22]22 ) However, the
   factors chosen by the legislature, such as number of employees,
   business property and registration fee, clearly had nothing to do with
   uniform income taxation of all undertakings. Nor had the United Kingdom
   made any attempt to explain those factors. ( [23]23 )

   49.

   In this regard, that judgment of the Court of Justice does represent an
   exception ( [24]24 ) to the principle set out above, according to which
   Member States have autonomy in determining the reference framework,
   because the Court in fact reviewed the creation of a reference
   framework in respect of the existence of aid. However, the Court did
   nothing more than carry out a kind of review of possible abuse in the
   exercise of national fiscal sovereignty. In essence, it merely verified
   whether the Member State acted consistently (and not abusively) in the
   exercise of its fiscal sovereignty.

   50.

   In that instance, it rightly found this not to be the case. The
   Gibraltar law on tax was intended solely to circumvent the rules on
   State aid by using purportedly general profit-based income taxation to
   establish very low taxation of certain companies which were intended to
   generate income (offshore companies). The Commission and the Court
   rightly considered this to constitute aid. The selective advantage
   resided in the internal inconsistency between the reasons for or
   objective of the law and the design of the law. Even though it was
   aimed at general profit-based income taxation of all undertakings
   established in Gibraltar, specific undertakings were intentionally made
   subject to only very low taxation. ( [25]25 )

   51.

   In that judgment, contrary to the assertion made by the Commission in
   the present case, the Court did not therefore substitute its own view
   of general normal taxation for that of the Member State. Nor did it
   rule that EU law prescribes a certain tax rate structure. It merely
   ruled correctly that general income taxation of all resident
   undertakings cannot be based on extrinsic factors, the objective of
   which is simply to favour certain undertakings that, as a rule, manage
   without large premises and without many staff, as was the case with
   offshore companies. ( [26]26 )

   52.

   In essence, the Court thus prevented Member States from abusing their
   general tax law in order to grant advantages to individual undertakings
   in circumvention of the rules on State aid. That abuse of fiscal
   autonomy resulted from a manifestly inconsistent design of the tax law
   for Gibraltar.

   (3) Consistency of the Hungarian advertisement tax

   53.

   There is no need for a more extensive examination in the case of
   generally applicable tax laws. If EU law respects the fiscal
   sovereignty of the Member States and if the rules on State aid do not
   prescribe any specific design for national tax systems, a generally
   applicable tax law - which just creates the reference framework - can
   constitute aid only if its design was manifestly inconsistent. ( [27]27
   )

   54.

   The examination of the selective advantage in the case of a generally
   applicable tax law is then reduced to just this one stage. The
   remaining - and still contestable - stages (how the correct reference
   framework is determined, are there exceptions or a counter-exception,
   are the differentiations specifically justified and who bears the
   burden of proof for what) can be omitted.

   55.

   Such inconsistency in the Hungarian advertisement tax was rightly found
   by the General Court not to exist. Thus, it asserts in paragraph 78 et
   seq. of the judgment under appeal that the normal system was the
   Hungarian law in its specific progressive structure, which resulted in
   heavier taxation of undertakings with a higher turnover and lower
   taxation of undertakings with a smaller turnover (paragraph 89). This
   followed from the redistributive purpose associated with a progressive
   rate (paragraph 88). Consequently, a selective advantage could not be
   inferred solely from the progressive structure (paragraph 105). Because
   the Commission did not assert or demonstrate any other inconsistency
   (paragraph 106 et seq.), the law in question could not be regarded as
   State aid.

   56.

   I am not convinced by the arguments against this view put forward by
   the Commission in the appeal. ( [28]28 )

   (i) Turnover-based income tax

   57.

   It is not inconsistent to create a turnover-based income tax. The
   Commission's arguments are ultimately all based on the idea that, in
   the taxation of financial capacity, regard should be had solely to
   profit (or efficiency, that is to say, profit margin). Only this
   properly reflects taxable capacity. At the hearing the Commission also
   repeatedly submitted that only profit-based income taxation is capable
   of correctly taxing ability to pay.

   58.

   The Commission fails to recognise that profit, too, is only a
   (notional) parameter for the uniform taxation of ability to pay. It
   says something about real ability to pay only to a limited extent, as
   is shown by the BEPS debate. ( [29]29 ) This worldwide debate arises
   because undertakings with high profits clearly do not pay the
   corresponding taxes as they are able to reduce the assessment bases
   significantly (`base erosion') or shift profits to low-tax countries
   (`profit shifting').

   59.

   Profit-based income taxation, like turnover-based income taxation, has
   its advantages and disadvantages. However, these must be weighed up and
   accounted for not by an authority or a court, but by a democratically
   mandated legislature. When drafting tax legislation, the legislature
   (here the Hungarian legislature) can decide which tax is, in its view,
   appropriate. In any case, the rules on State aid do not require the tax
   which is, in the Commission's view, most appropriate to be introduced.

   60.

   Contrary to the submission made by the Commission, a profit-based
   income tax is also not unquestionably preferable (in the words of the
   Commission `appropriate'). On the contrary, around the world
   turnover-based income taxes are on the rise, as is shown by the
   Commission's proposed digital services tax. ( [30]30 ) This uses annual
   turnover as the basis for the taxation of undertakings. The Hungarian
   advertisement tax and the planned EU digital services tax are no
   different in this respect.

   (ii) Progressive rate

   61.

   In addition, a progressive rate does not constitute an inconsistency
   per se. Progressive rates are a perfectly common means in income
   taxation of achieving taxation according to financial capacity. This
   holds both for profit-based income taxation and for turnover-based
   income taxation. Here too, the Commission's proposed digital services
   tax shows that a progressive rate structure is a common fiscal method
   of taxing particularly efficient undertakings.

   62.

   When, in its written pleadings, the Commission disputes that the
   proposed EU digital services tax has a progressive rate, this is
   correct only at first sight. Under Article 8 of the proposal, the rate
   is in fact 3% uniformly and is thus proportional. However, the
   Commission fails to recognise that any allowance in a proportional tax
   produces different average tax rates and thus a progressive rate
   curve. ( [31]31 ) It is similar with an exemption limit. The rate curve
   of the proposed turnover-based EU digital services tax, with its (two
   average) tax rates, ranges from 0% to 3%, while the average rate
   increases from 0% to 3% as turnover rises once the thresholds are
   exceeded. It is thus also progressive.

   63.

   Furthermore, the Commission's argument that a progressive rate
   structure is appropriate only for taxation of natural persons because
   it is only for them, according to the theory of marginal utility, that
   the individual utility gain is reduced as income increases, is also
   ineffective. Progressive rates would therefore be used only for
   taxation of natural persons.

   64.

   The Commission fails to understand that the theory of marginal utility
   is an economic theory and not a rule of law. Because `utility' cannot
   be measured, it has not been possible thus far to infer from that
   theory any definitive (legal) statements regarding the correct tax
   rate. ( [32]32 ) In the past, conversely, even proportional rates were
   considered discriminatory. ( [33]33 )

   65.

   The reason why, as the Commission rightly asserts, progressive rates
   tend to be used for taxation of natural persons would therefore seem to
   be that legal persons are able to evade the progressive effect
   arbitrarily through spin-offs or larger group structures. Nevertheless,
   this problem does not make progressive corporate taxation covering both
   natural and legal persons inconsistent.

   66.

   Moreover, the examples of taxation which the Commission cites and
   regards as unfair do not demonstrate any inconsistency. Thus, the
   Commission maintains that the Hungarian progressive rate is not an
   appropriate means because taxation is 155 times higher where turnover
   is 10 times higher. This example - which would seem to refer to the
   initial version of the Hungarian advertisement tax - merely shows,
   however, the logical consequences of a progressive tax curve. The EU
   digital services tax proposed by the Commission, with its exemption
   limits, produces even more extreme results. ( [34]34 )

   67.

   Aside from this, the criterion of appropriateness is in any case the
   wrong criterion. As was stated above (point 59), the appropriateness of
   a national tax must be assessed by the national legislature. The rules
   on State aid, in a case where the reference framework is only just
   determined, can merely eliminate inconsistencies. The Hungarian
   advertisement tax nevertheless implements the progressive tax structure
   consistently.

   (b)   Conclusion

   68.

   Consequently, the General Court was right to reject the existence of
   aid within the meaning of Article 107(1) TFEU. The first part of the
   first ground of appeal is unfounded and must therefore be rejected.

   (c)   In the alternative: normal standard of review of a selective
   advantage

   69.

   Even if, in examining a general tax law like the one at issue, the
   Court were not to confine itself to a review of consistency, it is not
   evident that the General Court erred in law in rejecting the existence
   of aid.

   70.

   According to the normal standard of review, it is necessary to begin by
   identifying the ordinary or `normal' tax system applicable in the
   Member State concerned. It is in relation to that ordinary or `normal'
   tax regime that it is necessary, secondly, to assess whether the
   advantage granted by the tax measure in question is an unjustified
   exception and therefore selective. ( [35]35 )

   71.

   The latter point requires there to be unequal treatment of undertakings
   in a comparable situation which cannot be justified. ( [36]36 ) A
   measure which constitutes an exception to the application of the
   general tax system may be justified if the Member State concerned can
   show that that measure results directly from the basic or guiding
   principles of its tax system. ( [37]37 ) In essence, this selectivity
   test is a discrimination test. ( [38]38 )

   72.

   The General Court rightly found that the Commission chose the incorrect
   reference framework. The relevant reference framework can only be the
   prevailing national law and not hypothetical or notional law. Anything
   else would permit the Commission to replace the respective national
   legislature and to determine its favoured tax system as the reference
   framework.

   73.

   In so far as the Commission relies in this regard on the Court's ruling
   in the Gibraltar judgment, as has already been stated above in point 47
   et seq., it misunderstands the statements made there. In that judgment
   the Court certainly did not create a notional reference framework
   itself.

   74.

   The choice of the incorrect reference framework by the Commission, as
   the Court has ruled, ( [39]39 ) necessarily `vitiates the whole of the
   analysis of the condition relating to selectivity.' For this reason,
   the contested negative decision should be annulled. The first part of
   the first ground of appeal is therefore also unfounded on application
   of the normal standard of review.

   2.   The other two parts of the first ground of appeal

   75.

   By the other two parts of the first ground of appeal, the Commission
   objects to the additional considerations put forward by the General
   Court and alleges that there, too, it wrongly rejected the existence of
   aid. Since, according to paragraphs 84 and 85 of the judgment under
   appeal, the additional considerations put forward by the General Court
   only examine whether a different conclusion follows from the Court's
   ruling in the Gibraltar judgment, which has already been found not to
   be the case above (point 47 et seq.), no further examination of the
   other parts of the first ground of appeal is necessary.

   76.

   The General Court did, however, further examine whether aid
   nevertheless exists. The Court possibly assumed in paragraphs 84
   and 85, to the benefit of the Commission, that in the contested
   decisions the Commission also used the correct reference framework (a
   progressive turnover-based business tax) and affirmed the existence of
   aid on that basis. Otherwise, the further examination of the
   comparability of the situations and the justification of a difference
   in treatment would not make any sense. The General Court also rejected
   the existence of aid in this respect. This point is contested by the
   Commission with the other two parts of the first ground of appeal. At
   the hearing it became clear that the Commission alleges in particular
   that the General Court rejected the comparability of undertakings with
   high and low turnovers.

   (a)   In the alternative: second part of the first ground of appeal -
   comparability of higher-turnover and lower-turnover undertakings

   77.

   Consequently - and because there was a lengthy discussion on the
   subject between the parties at the hearing - it will be examined in the
   alternative whether also on this premiss (assumption of the correct
   reference framework by the Commission) the General Court did not err in
   law by rejecting a selective advantage. The Commission considers it an
   error in law that the Court rejected the comparability of
   lower-turnover and higher-turnover undertakings in so far as it had
   regard to the wrong legislative objective (second part of the first
   ground of appeal).

   78.

   This part of the first ground of appeal is also unfounded. If the
   progressive turnover-based income tax is the actual reference
   framework, the consistent implementation of that reference framework is
   not an exception that should somehow be justified, but the rule.

   79.

   Furthermore, within that reference framework there is no discernible
   unjustifiable difference in treatment of undertakings in a comparable
   situation. Larger and smaller retailers differ in that reference system
   precisely on account of their turnover and resulting financial
   capacity. In the view of the Member State - which is not manifestly
   incorrect here (with regard to consistency see above, point 53 et
   seq.) - they are not in a legally and factually comparable situation.

   80.

   The Commission, on the other hand, clearly considers that it follows
   from the objective of a tax of generating revenue for the national
   budget that each taxable person should be taxed at the same (relative)
   level. Accordingly, the General Court should have had regard, in
   relation to comparability, only to the objective of generating tax
   revenue. The volume of turnover is irrelevant to that objective and,
   for that reason, lower taxation of undertakings with low turnovers
   cannot be justified.

   81.

   This line of argument cannot be accepted. In the context of a review of
   State aid, the objective of a tax cannot be limited to the generation
   of revenue. Rather, the crucial factor is the specific taxation
   objective pursued by the legislature in drafting taxation
   legislation, ( [40]40 ) which is evident by way of interpretation from
   the nature of the tax and its design. An intrinsic objective of a
   progressive tax is absolute and relatively higher taxation of taxable
   persons with a higher ability to pay. This should therefore also be
   taken into consideration in examining comparability, as the General
   Court rightly did.

   82.

   The General Court stated in this regard in paragraph 89 of the judgment
   under appeal that it may reasonably be presumed that an undertaking
   which achieves a high turnover may, because of various economies of
   scale, have proportionately lower costs than an undertaking with a
   smaller turnover and is therefore capable of paying more in terms of
   tax. This too cannot be criticised from a legal point of view. As the
   Court has already held, ( [41]41 ) the level of turnover can certainly
   represent a relevant indicator of taxable capacity.

   83.

   This is suggested, first, by the fact that high profits are not
   actually possible without high turnover and, second, by the fact that
   as a rule the profit from additional turnover (marginal profit)
   increases with falling fixed unit costs. It would not therefore appear
   unreasonable to regard turnover, as a reflection of an undertaking's
   size or market position and potential profits, also as a reflection of
   its financial capacity and to tax it on that basis. ( [42]42 )

   84.

   As emerged at the hearing, the Commission has deliberated a great deal
   about the correct taxation of ability to pay. In this exercise, the
   disadvantages of a turnover-based income tax have rightly been
   highlighted and potentially more sensible alternatives demonstrated. It
   is unclear, however, what bearing these very profound fiscal
   considerations have on the rules on State aid. Nor did the Commission
   answer an enquiry made by the Court in this regard at the hearing. It
   may be that a profit calculation by means of a balance sheet comparison
   is more precise than linking to net turnover. Contrary to the view
   taken by the Commission, however, the rules on State aid do not inquire
   about a more sensible or a more precise tax system, but the selective
   favouring of certain undertakings over others in the same situation.

   85.

   The second part of the first ground of appeal is therefore also
   unfounded.

   (b)   In the alternative: third part of the first ground of appeal:
   justification of a differentiation

   86.

   By the third part of the first ground of appeal, the Commission alleges
   that the General Court erred in law because it took external reasons
   into consideration in connection with the justification of a difference
   in treatment.

   87.

   This part of the appeal is based on the misassumption that there is a
   difference in treatment of comparable taxable persons, as only then
   does the question of a justification arise. Because that is not the
   case, as has been explained above, this part of the appeal is examined
   only in the alternative in the event that, against expectations, the
   Court considers a retailer with a monthly net turnover of, for example,
   EUR/HUF 50000 and a retailer with a monthly net turnover of, for
   example, EUR/HUF 200 million to be in a comparable situation.

   88.

   It would then have to be assessed whether the General Court was wrong
   to consider the difference in treatment connected with the different
   average rate of a progressive tax to be justified. Contrary to the
   Commission's view, justifications other than purely fiscal reasons are
   conceivable justifications for a difference in treatment. In this
   respect, plausible non-fiscal reasons can also justify a
   differentiation, as was acknowledged, for example, in ANGED with regard
   to environmental and town and country planning reasons in connection
   with a tax on retail sales area. ( [43]43 )

   89.

   In the present case, the General Court did not take into consideration
   any incorrect justifications. In paragraphs 89 and 90 of the judgment
   under appeal, the Court considered the different average rate to be
   justified in the light of the principle of taxation according to
   ability to pay and the objective thereby pursued of the redistribution
   of the tax burden between taxable persons with higher capacity and
   taxable persons with less capacity.

   90.

   This cannot be criticised from a legal point of view. Nor can it be
   stated that the progressive tax scale of the Hungarian advertisement
   tax is not based in the specific tax legislation itself, but pursues
   purposes which are extrinsic to it and extraneous. ( [44]44 ) The
   volume of turnover indicates (without manifest error at least) a
   certain financial capacity. Accordingly, as the Commission itself shows
   with the proposal for a digital services tax, ( [45]45 ) turnover can
   also be seen as a (slightly rougher) indicator of greater economic
   power, and thus greater financial capacity.

   91.

   Furthermore, the principle of the welfare state - which the European
   Union recognises in Article 3(3) TEU - also justifies a progressive tax
   rate which imposes a heavier burden, even in relative terms, on those
   with greater financial capacity than on taxable persons with not quite
   so much financial capacity. This applies at least in the case of a tax
   which also covers natural persons, which is the situation here.

   92.

   The Commission's criticism that in paragraph 106 of the judgment under
   appeal the General Court disregarded the burden of proof is also
   ineffective. It is based on the incorrect view that turnover-based
   progressive taxes are per se aid requiring justification.

   3.   Conclusion

   93.

   The first ground of appeal raised by the Commission is therefore
   unfounded in its entirety.

   B. Second ground of appeal: misinterpretation of Article 107(1) TFEU in
   respect of the possibility of using losses in the first year

   94.

   By the second ground of appeal, an error in law in the application of
   Article 107(1) TFEU is alleged on the ground that the General Court
   wrongly did not consider the possibility of using losses in the first
   year to be a selective advantage.

   95.

   The General Court held in paragraph 118 of the judgment under appeal
   that certain tax variations, taking into account specific situations,
   must not be analysed as constituting a selective advantage. This
   applies even if they do not stem from the actual nature of the
   reference tax system, that is from its objective, if those provisions
   do not contravene the objective of the tax in question and are not
   discriminatory.

   96.

   This is essentially consistent with the case-law of the Court of
   Justice, according to which, in substance, a tax regime is not
   selective if it is applicable without distinction to all economic
   operators. ( [46]46 ) Nor can the selectivity of the tax regime be
   inferred from the fact that it grants an advantage only to undertakings
   satisfying its conditions, in this case the existence of losses in the
   previous year. ( [47]47 )

   97.

   Rather, taking the correct reference framework as the basis, there must
   be unequal treatment of undertakings in a comparable situation which
   cannot be justified. ( [48]48 ) A measure which constitutes an
   exception to the application of the general tax system may be justified
   if the Member State concerned can show that that measure results
   directly from the basic or guiding principles of its tax system, (
   [49]49 ) while plausible non-fiscal reasons can also justify a
   corresponding fiscal differentiation. ( [50]50 )

   1.   Part of or exception to the reference system?

   98.

   In so far as a general tax law is at issue, difficulties arise above
   all in determining the reference framework (often also referred to as
   the reference system), as the tax in question has only just been
   created by the law to be reviewed. In the Commission's view,
   turnover-based taxation without the possibility of using losses must be
   regarded as the reference system. By contrast, Hungary and also, it
   would appear, the General Court regard the newly introduced law itself
   as the reference system, which thus consists in a turnover-based tax
   with the possibility of using losses in the first year of the newly
   introduced tax.

   99.

   In the latter case there would be only a review of the consistency of
   the national tax law (for details, see above under point 53 et seq.).
   In the former case it is crucial whether loss-making taxable persons
   and non-loss-making taxable persons are in a comparable situation and,
   if so, whether the Member State concerned can show that the exception
   is justified. In the Commission's view, only certain reasons are
   available to it as possible justifications.

   100.

   However, the question whether the possibility of using losses is to be
   considered as part of the taxation system or as an exception to it
   cannot be answered sufficiently clearly. In a profit-based income tax
   system, a possibility of using losses would seem to be considered
   unquestionably as part of the taxation system. In turnover-based income
   taxation, as the Commission argues, it could certainly be regarded as
   an exception to the system. On the other hand, the Hungarian
   legislature took that `exception' as the basis for the first year of
   its turnover-based income tax system. It is thus a priori also a part
   of the system.

   101.

   The underlying reason for the national regime at issue is ultimately to
   alleviate the effects of a turnover-based income tax for undertakings
   which, despite high turnovers in the year in which the tax was
   introduced, were loss-making in the previous year and are now
   confronted in the current year with a new non-profit-related tax. As
   Hungary also asserts, this is nothing more than a transitional measure
   to alleviate the particular effects of the advertisement tax for the
   first tax year, for reasons of proportionality, in particular because
   the advertisement tax was introduced in the current year.

   102.

   Upon closer inspection, this transitional measure even takes the
   Commission's concerns into account to some extent. The Commission
   consistently puts forward the argument, in connection with the first
   ground of appeal (progressive rate), that a turnover-based tax is
   inappropriate for taxing taxable persons according to financial
   capacity because even undertakings with high turnovers might have only
   small profits and still be required to pay taxes. A lack of capacity in
   the previous year is taken into consideration proportionally in the
   first year of the tax.

   103.

   In essence, a possibility of using losses which is confined to the
   first tax year achieves coordination, for a limited period of time
   (transitionally), between two tax systems, namely the profit-based
   corporate/income tax and the turnover-based (non-profit-related)
   advertisement tax. However, I find it hard to describe coordination,
   provided for in law, between two tax systems as an exception to a
   reference system. Rather, it is part of the (coordinated) reference
   system.

   104.

   Such coordination also exists in the corporate tax system in Hungary.
   As Hungary has asserted, the advertisement tax can be deducted from the
   corporate tax base. Naturally, only profit-making undertakings `profit'
   from this. It is obviously not correct, however, to understand this as
   an exception in the corporate tax system requiring justification. It is
   unclear to me why the situation should be different for a coordinating
   measure in the system of the advertisement tax, even if it has effect
   for only one year. In addition, as Hungary asserts, the possibility of
   using losses is intended to compensate for the `disadvantage' suffered
   by loss-making undertakings which, in the absence of profit, could not
   avail themselves of the advertisement tax to offset profits in the
   context of corporate tax or income tax.

   105.

   Because the decision whether the possibility of using losses is now to
   be considered as part of the reference system or as an exception to the
   reference system depends crucially on the understanding of national law
   and also to a large extent on which level is taken as the basis, the
   scope of the review of a selective advantage should not be contingent
   on that classification. Rather, the review should be carried out in a
   uniform manner so as to leave this distinction open.

   2.   Review of consistency also for exceptions to the reference system

   106.

   I therefore propose that the Court conduct a single review of
   consistency for general rules within a tax law in the light of the
   Member States' fiscal sovereignty in both cases (whether now as part of
   the just created reference system or as an exception within the
   reference system). General differentiations, which are applicable
   without distinction to all ( [51]51 ) and cover only taxable persons
   that also fulfil the factual preconditions ( [52]52 ) and are part of a
   consistent tax system cannot normally constitute a selective
   advantage. ( [53]53 ) In this respect, general differentiations in a
   tax law constitute selective measures only if they have no rational
   basis in the light of the objective of the law and are thus not
   explainable.

   107.

   On the basis of this lower standard of review, a selective advantage is
   possible only where, first, that measure (here the possibility of using
   losses) introduces differentiations between economic operators which
   are no longer plausible. That would be the case, for example, if the
   taxable persons, in the light of the objective attributed to the tax
   system of the Member State concerned, are in a comparable factual and
   legal situation. ( [54]54 )

   108.

   Even if that condition is fulfilled, second, the favouring can be
   justified, according to settled case-law, by the nature or general
   scheme of the system of which it is part. This must be considered in
   particular if a tax regime results directly from the basic or guiding
   principles of the national tax system, ( [55]55 ) which, on the basis
   of the fiscal autonomy of the Member State in the context of the review
   of consistency, simply have to be plausible. Furthermore, plausible
   non-fiscal reasons can also justify a differentiation, as was
   acknowledged, for example, in ANGED with regard to environmental and
   town and country planning reasons in connection with a tax on retail
   sales area. ( [56]56 )

   109.

   The General Court ultimately carried out such a review of consistency.
   It correctly examined whether the regime is discriminatory or whether
   it is explainable in the light of the tax system (and not therefore
   contrary to the objective of the tax in question). Since the fact that
   losses existed in the previous year is an objective criterion and
   undertakings with losses and undertakings with profits in the previous
   year are different in terms of the ability to bear additional
   non-profit-related taxation, the General Court rightly rejected a
   selective advantage in paragraph 122 of the judgment under appeal.

   110.

   On the other hand, in so far as the Commission seeks to infer the
   discriminatory effect solely from the fact that when the law was
   enacted in mid-2014 it was already clear which undertakings were
   loss-making in 2013, that approach is not convincing. First, it
   presupposes that the relevant tax returns had to be submitted by that
   date in Hungary, which depends on the national law of tax procedure and
   falls outside the scope of the knowledge of the Court. Second, the
   legislature would have had to have known those figures, which is fairly
   unlikely. There is nothing in the entire procedure to indicate that the
   regime was specifically intended to `favour' certain undertakings.

   111.

   The Commission's argument that a use of losses is incompatible with a
   non-profit-related, turnover-based tax is likewise unconvincing. A
   transitional measure which, for reasons of proportionality, alleviates
   the particular effects of the non-profit-related advertisement tax in
   respect of the first tax year for undertakings which were loss-making
   in the previous year is not incompatible. As has already been explained
   (see above, point 103 et seq.), it is a matter of plausible
   coordination of two taxation systems during a transitional period.

   112.

   To infer discrimination from the fact that losses were used only in the
   first year of the advertisement tax and not in further years, as the
   Commission attempts to do, represents a failure to understand the
   purpose of a transitional measure. A transitional measure is intended
   per se for a limited period. In addition, in paragraph 123 of the
   judgment under appeal the General Court rightly held that the principle
   of periodicity which applies in tax law certainly permits different
   regimes for different tax periods. The situations prevailing in
   different tax periods are thus not comparable with one another.

   113.

   The Commission's view that undertakings with profits and undertakings
   with losses in the previous year are comparable in every respect in the
   light of the purpose of the advertisement tax is also unconvincing. As
   was explained above under point 55 et seq., the objective of the
   advertisement tax, which is progressive in nature, consists in a degree
   of redistribution of the tax burden according to financial capacity,
   which is determined on the basis of turnover. The presumption made by
   the Hungarian legislature that, because of a lower level of liquidity
   or less financial reserves, undertakings with losses in the previous
   year are more severely affected by a non-profit-related tax than
   undertakings with profits in the previous year is plausible. In the
   view of the Member State - which is not manifestly incorrect here -
   they are not in a legally and factually comparable situation.

   3.   In the alternative: justification of the possibility of using
   losses

   114.

   Furthermore, a difference in treatment by reason of the different basic
   situation of the two comparison groups in the first year of the
   advertisement tax would also be justified.

   115.

   As the Court held in World Duty Free Group, ( [57]57 ) only the
   examination of the difference in treatment in question in the light of
   the objective pursued by the legislation is decisive. However,
   consideration must be given not only to the objectives expressly
   mentioned in the national legislation, but also to the objectives which
   can be inferred from the national legislation by way of
   interpretation. ( [58]58 ) Otherwise, regard would be had solely to the
   legislative technique, even though, in the rules on State aid, State
   interventions are to be assessed on the basis of their effects,
   independently of the techniques used. ( [59]59 )

   116.

   The alleviation of the effects of the newly introduced
   non-profit-related tax on undertakings with no profits in the previous
   year is objectively justified in the light of the objectives of the
   advertisement tax. There is no need to determine whether this
   constitutes an internal fiscal purpose or an external purpose since
   that is immaterial, as was explained above in point 88 et seq. The
   intention is to mitigate hardships arising from an additional tax for
   undertakings with losses in the previous year. Account is thus taken of
   the diminished ability of the taxable person to pay an additional
   non-profit-related tax.

   4.   Conclusion

   117.

   The possibility of using losses for the first tax year is plausible and
   not arbitrary. The associated difference in treatment of operators in
   the first year of the advertisement tax is not therefore a selective
   advantage. No error in law by the General Court can be established in
   this regard. Accordingly, the second ground of appeal raised by the
   Commission is also unfounded.

   VI. Costs

   118.

   Under Article 184(2) of the Rules of Procedure of the Court of Justice,
   where the appeal is unfounded, the Court is to make a decision as to
   costs. Under Article 138(1), which applies to the procedure on appeal
   in accordance with Article 184(1) thereof, the unsuccessful party is to
   be ordered to pay the costs if they have been applied for in the
   successful party's pleadings. Because the Commission has been
   unsuccessful, it must be ordered to pay the costs.

   119.

   Under Article 184(1) in conjunction with Article 140(1), the Republic
   of Poland, as intervener, must bear its own costs.

   VII. Conclusion

   120.

   In the light of the foregoing, I propose that the Court should:

   1.

   Dismiss the appeal brought by the Commission.

   2.

   Order the European Commission to bear its own costs and to pay the
   costs of Hungary.

   3.

   Order the Republic of Poland to bear its own costs.
     __________________________________________________________________

   ( [60]1 ) Original language: German.

   ( [61]2 ) The first time it did so was in the judgment of 15 November
   2011, Commission and Spain v Government of Gibraltar and United Kingdom
   ([62]C-106/09 P and C-107/09 P, [63]EU:C:2011:732), where the
   Commission brought proceedings against the new corporate tax law for
   Gibraltar. The situation was similar in the judgments of 26 April 2018,
   ANGED ([64]C-233/16, [65]EU:C:2018:280), of 26 April 2018, ANGED
   ([66]C-234/16 and C-235/16, [67]EU:C:2018:281), and of 26 April 2018,
   ANGED ([68]C-236/16 and C-237/16, [69]EU:C:2018:291).

   ( [70]3 ) Proposal for a Council Directive on the common system of a
   digital services tax on revenues resulting from the provision of
   certain digital services, 21 March 2018, COM(2018) 148 final.

   ( [71]4 ) The proceedings are pending before the Court as Case
   C-562/19 P.

   ( [72]5 ) Judgments of 3 March 2020, Tesco-Global Áruházak
   ([73]C-323/18, [74]EU:C:2020:140), and of 3 March 2020, Vodafone
   Magyarország ([75]C-75/18, [76]EU:C:2020:139).

   ( [77]6 ) Judgment of 27 June 2019, Hungary v Commission ([78]T-20/17,
   [79]EU:T:2019:448).

   ( [80]7 ) Council Regulation of 13 July 2015 laying down detailed rules
   for the application of Article 108 of the Treaty on the Functioning of
   the European Union ([81]OJ 2015 L 248, p. 9).

   ( [82]8 ) [83]OJ 2017 L 49, p. 36.

   ( [84]9 ) Order of 23 March 2017, Hungary v Commission ([85]T-20/17 R,
   not published, [86]EU:T:2017:203).

   ( [87]10 ) Judgments of 27 June 2017, Congregación de Escuelas Pías
   Provincia Betania ([88]C-74/16, [89]EU:C:2017:496, paragraph [90]38);
   of 21 December 2016, Commission v World Duty Free Group and Others
   ([91]C-20/15 P and C-21/15 P, [92]EU:C:2016:981, paragraph [93]53); and
   of 21 December 2016, Commission v Hansestadt Lübeck ([94]C-524/14 P,
   [95]EU:C:2016:971, paragraph [96]40).

   ( [97]11 ) See also, to that effect, judgments of 21 December 2016,
   Commission v World Duty Free Group and Others ([98]C-20/15 P
   and C-21/15 P, [99]EU:C:2016:981, paragraph [100]54), and of 14 January
   2015, Eventech ([101]C-518/13, [102]EU:C:2015:9, paragraph [103]53);
   see also, expressly outside the field of tax law, judgment of
   21 December 2016, Commission v Hansestadt Lübeck ([104]C-524/14 P,
   [105]EU:C:2016:971, paragraphs [106]53 and [107]55).

   ( [108]12 ) See, inter alia, judgment of 19 December 2018, A-Brauerei
   ([109]C-374/17, [110]EU:C:2018:1024, paragraph [111]36).

   ( [112]13 ) See Opinion of Advocate General Saugmandsgaard Ře in
   A-Brauerei ([113]C-374/17, [114]EU:C:2018:741, point [115]61 et seq.);
   Opinion of Advocate General Wahl in Andres v Commission
   ([116]C-203/16 P, [117]EU:C:2017:1017, point [118]88 et seq.); and my
   Opinions in Tesco-Global Áruházak ([119]C-323/18, [120]EU:C:2019:567,
   point [121]151 et seq.); in Vodafone Magyarország ([122]C-75/18,
   [123]EU:C:2019:492, point [124]163 et seq.); in ANGED ([125]C-233/16,
   [126]EU:C:2017:852, point [127]76 et seq.); in ANGED ([128]C-234/16
   and C-235/16, [129]EU:C:2017:853, point [130]74 et seq.); and in ANGED
   ([131]C-236/16 and C-237/16, [132]EU:C:2017:854, point [133]76 et
   seq.).

   ( [134]14 ) Judgments of 27 June 2017, Congregación de Escuelas Pías
   Provincia Betania ([135]C-74/16, [136]EU:C:2017:496,
   paragraph [137]65), and of 9 October 2014, Ministerio de Defensa and
   Navantia ([138]C-522/13, [139]EU:C:2014:2262, paragraph [140]21);
   similarly, judgment of 15 November 2011, Commission and Spain v
   Government of Gibraltar and United Kingdom ([141]C-106/09 P
   and C-107/09 P, [142]EU:C:2011:732, paragraph [143]71 - `normally
   included in the budget').

   ( [144]15 ) See, inter alia, judgments of 9 October 2014, Ministerio de
   Defensa and Navantia ([145]C-522/13, [146]EU:C:2014:2262,
   paragraph [147]23); of 15 November 2011, Commission and Spain v
   Government of Gibraltar and United Kingdom ([148]C-106/09 P
   and C-107/09 P, [149]EU:C:2011:732, paragraph [150]72); and of 15 March
   1994, Banco Exterior de Espańa ([151]C-387/92, [152]EU:C:1994:100,
   paragraph [153]14).

   ( [154]16 ) Judgments of 27 June 2017, Congregación de Escuelas Pías
   Provincia Betania ([155]C-74/16, [156]EU:C:2017:496,
   paragraph [157]66); of 19 March 2013, Bouygues and Bouygues Télécom v
   Commission ([158]C-399/10 P and C-401/10 P, [159]EU:C:2013:175,
   paragraph [160]101); of 15 November 2011, Commission and Spain v
   Government of Gibraltar and United Kingdom ([161]C-106/09 P
   and C-107/09 P, [162]EU:C:2011:732, paragraph [163]71); and of 15 March
   1994, Banco Exterior de Espańa ([164]C-387/92, [165]EU:C:1994:100,
   paragraph [166]13).

   ( [167]17 ) See judgments of 19 December 2018, A-Brauerei
   ([168]C-374/17, [169]EU:C:2018:1024, paragraph [170]28); of 28 June
   2018, Andres (Insolvenz Heitkamp BauHolding) v Commission
   ([171]C-203/16 P, [172]EU:C:2018:505, paragraph [173]97); of
   21 December 2016, Commission v World Duty Free Group and Others
   ([174]C-20/15 P and C-21/15 P, [175]EU:C:2016:981, paragraph [176]68);
   of 8 September 2011, Paint Graphos ([177]C-78/08 to C-80/08,
   [178]EU:C:2011:550); and of 10 January 2006, Cassa di Risparmio di
   Firenze and Others ([179]C-222/04, [180]EU:C:2006:8,
   paragraph [181]132).

   ( [182]18 ) Judgment of 3 March 2020, Tesco-Global Áruházak
   ([183]C-323/18, [184]EU:C:2020:140, paragraph [185]69), and of 3 March
   2020, Vodafone Magyarország ([186]C-75/18, [187]EU:C:2020:139,
   paragraph [188]49).

   ( [189]19 ) Judgment of 3 March 2020, Tesco-Global Áruházak
   ([190]C-323/18, [191]EU:C:2020:140, paragraph [192]70), and of 3 March
   2020, Vodafone Magyarország ([193]C-75/18, [194]EU:C:2020:139,
   paragraph [195]50).

   ( [196]20 ) Judgments of 26 April 2018, ANGED ([197]C-233/16,
   [198]EU:C:2018:280, paragraph [199]50), and of 15 November 2011,
   Commission and Spain v Government of Gibraltar and United Kingdom
   ([200]C-106/09 P and C-107/09 P, [201]EU:C:2011:732,
   paragraph [202]97).

   ( [203]21 ) [204]OJ 2016 C 262, p. 1.

   ( [205]22 ) See judgment of 15 November 2011, Commission and Spain v
   Government of Gibraltar and United Kingdom ([206]C-106/09 P
   and C-107/09 P, [207]EU:C:2011:732, paragraph [208]12).

   ( [209]23 ) See judgment of 15 November 2011, Commission and Spain v
   Government of Gibraltar and United Kingdom ([210]C-106/09 P
   and C-107/09 P, [211]EU:C:2011:732, paragraphs [212]149 and [213]150).

   ( [214]24 ) The judgment of 19 December 2018, A-Brauerei
   ([215]C-374/17, [216]EU:C:2018:1024, paragraph [217]32) would also seem
   to be along similar lines.

   ( [218]25 ) See, expressly, judgment of 15 November 2011, Commission
   and Spain v Government of Gibraltar and United Kingdom ([219]C-106/09 P
   and C-107/09 P, [220]EU:C:2011:732, paragraphs [221]99, [222]102
   and [223]106).

   ( [224]26 ) See expressly judgment of 15 November 2011, Commission and
   Spain v Government of Gibraltar and United Kingdom ([225]C-106/09 P
   and C-107/09 P, [226]EU:C:2011:732, paragraph [227]106).

   ( [228]27 ) See also, in that sense, my Opinions in Tesco-Global
   Áruházak ([229]C-323/18, [230]EU:C:2019:567, point [231]151 et seq.);
   Vodafone Magyarország ([232]C-75/18, [233]EU:C:2019:492, point [234]170
   et seq.); and ANGED ([235]C-233/16, [236]EU:C:2017:852, point [237]81
   et seq.).

   ( [238]28 ) These are more or less the same arguments as were made
   during the proceedings in Tesco-Global Áruházak ([239]C-323/18,
   [240]EU:C:2020:140) and Vodafone Magyarország ([241]C-75/18,
   [242]EU:C:2020:139).

   ( [243]29 ) See, inter alia, the OECD `Action Plan on Base Erosion and
   Profit shifting' - available at
   https://www.oecd.org/ctp/BEPSActionPlan.pdf - p. 13: `Fundamental
   changes are needed to effectively prevent double non-taxation, as well
   as cases of no or low taxation associated with practices that
   artificially segregate taxable income from the activities that generate
   it.'

   ( [244]30 ) Proposal for a Council Directive on the common system of a
   digital services tax on revenues resulting from the provision of
   certain digital services, 21 March 2018, COM(2018) 148 final.

   ( [245]31 ) See my comments in the Opinions in Tesco-Global Áruházak
   ([246]C-323/18, [247]EU:C:2019:567, point [248]1, footnote 3), and
   Vodafone Magyarország ([249]C-75/18, [250]EU:C:2019:492, point [251]3,
   footnote 4).

   ( [252]32 ) See, inter alia and very succinctly, Birk/Desens/Tappe
   (ed.), Steuerrecht, 22nd edition 2019, paragraph 38.

   ( [253]33 ) For example, back in 1958, Bundesverfassungsgericht
   (Federal Constitutional Court), judgment of 24 June 1958 - 2 BvF 1/57
   Az., BVerfGE 8, 51 (68 and 69): `Fairness dictates here that, in the
   spirit of proportional equality, the economically stronger should pay a
   higher percentage of their income as tax than the economically weaker.'

   ( [254]34 ) Under the Commission's proposal, an undertaking with a
   worldwide turnover above EUR 750 million that does not exceed the limit
   of EUR 50 million within the EU (turnover precisely EUR 50 million)
   pays exactly EUR 0 in tax. Another undertaking with a worldwide
   turnover above EUR 750 million that exceeds the exemption limit of
   EUR 50 million within the EU by EUR 450 million pays EUR 15 million in
   tax. Turnover that is 10 times higher within the EU (EUR 500 million
   rather than EUR 50 million) results in an infinitely higher tax burden.

   ( [255]35 ) See, inter alia, judgment of 19 December 2018, A-Brauerei
   ([256]C-374/17, [257]EU:C:2018:1024, paragraph [258]36).

   ( [259]36 ) Judgment of 21 December 2016, Commission v World Duty Free
   Group and Others ([260]C-20/15 P and C-21/15 P, [261]EU:C:2016:981,
   paragraph [262]58); see also, to that effect, judgments of 29 March
   2012, 3M Italia ([263]C-417/10, [264]EU:C:2012:184, paragraph [265]40);
   of 8 September 2011, Paint Graphos ([266]C-78/08 to C-80/08,
   [267]EU:C:2011:550, paragraphs [268]64 and [269]65); and of 29 April
   2004, Netherlands v Commission ([270]C-159/01, [271]EU:C:2004:246,
   paragraphs [272]42 and [273]43).

   ( [274]37 ) Judgments of 18 July 2013, P ([275]C-6/12,
   [276]EU:C:2013:525, paragraph [277]22), and of 8 September 2011, Paint
   Graphos ([278]C-78/08 to C-80/08, [279]EU:C:2011:550, paragraph [280]65
   and the case-law cited).

   ( [281]38 ) Opinion of Advocate General Bobek in Belgium v Commission
   ([282]C-270/15 P, [283]EU:C:2016:289, point [284]29).

   ( [285]39 ) Judgment of 28 June 2018, Andres (Insolvenz Heitkamp
   BauHolding) v Commission ([286]C-203/16 P, [287]EU:C:2018:505,
   paragraph [288]107).

   ( [289]40 ) As was also held by the Court in its judgments of
   19 December 2018, A-Brauerei ([290]C-374/17, [291]EU:C:2018:1024,
   paragraph [292]48 et seq. - objectives attributed to a particular tax
   scheme); of 26 April 2018, ANGED ([293]C-233/16, [294]EU:C:2018:280,
   paragraph [295]55 - in the light of the objectives pursued by the
   legislation); of 21 December 2016, Commission v World Duty Free Group
   and Others ([296]C-20/15 P and C-21/15 P, [297]EU:C:2016:981,
   paragraph [298]85); and of 15 November 2011, Commission and Spain v
   Government of Gibraltar and United Kingdom ([299]C-106/09 P
   and C-107/09 P, [300]EU:C:2011:732, paragraph [301]95 - in the light of
   the tax regime at issue).

   ( [302]41 ) Judgments of 3 March 2020, Tesco-Global Áruházak
   ([303]C-323/18, [304]EU:C:2020:140, paragraph [305]70), and of 3 March
   2020, Vodafone Magyarország ([306]C-75/18, [307]EU:C:2020:139,
   paragraph [308]50).

   ( [309]42 ) See my Opinions in Tesco-Global Áruházak ([310]C-323/18,
   [311]EU:C:2019:567, point [312]101); in Vodafone Magyarország
   ([313]C-75/18, [314]EU:C:2019:492, point [315]121 et seq.); and in
   Hervis Sport- és Divatkereskedelmi ([316]C-385/12, [317]EU:C:2013:531,
   point [318]61).

   ( [319]43 ) Judgments of 26 April 2018, ANGED ([320]C-236/16
   and C-237/16, [321]EU:C:2018:291, paragraph [322]40 et seq.); of
   26 April 2018, ANGED ([323]C-234/16 and C-235/16, [324]EU:C:2018:281,
   paragraph [325]45 et seq.); and of 26 April 2018, ANGED ([326]C-233/16,
   [327]EU:C:2018:280, paragraph [328]52 et seq.).

   ( [329]44 ) See, expressly, judgment of 8 September 2011, Paint Graphos
   ([330]C-78/08 to C-80/08, [331]EU:C:2011:550, paragraph [332]70).

   ( [333]45 ) Proposal for a Council Directive on the common system of a
   digital services tax on revenues resulting from the provision of
   certain digital services, 21 March 2018, COM(2018) 148 final.

   ( [334]46 ) See, inter alia, judgments of 21 December 2016, Commission
   v World Duty Free Group and Others ([335]C-20/15 P and C-21/15 P,
   [336]EU:C:2016:981, paragraph [337]53 et seq.); of 9 October 2014,
   Ministerio de Defensa and Navantia ([338]C-522/13, [339]EU:C:2014:2262,
   paragraph [340]23); of 29 March 2012, 3M Italia ([341]C-417/10,
   [342]EU:C:2012:184, paragraph [343]39); of 15 November 2011, Commission
   and Spain v Government of Gibraltar and United Kingdom ([344]C-106/09 P
   and C-107/09 P, [345]EU:C:2011:732, paragraph [346]73); and of
   8 November 2001, Adria-Wien Pipeline and Wietersdorfer & Peggauer
   Zementwerke ([347]C-143/99, [348]EU:C:2001:598, paragraph [349]35).

   ( [350]47 ) See to that effect, in particular, judgments of 19 December
   2018, A-Brauerei ([351]C-374/17, [352]EU:C:2018:1024,
   paragraph [353]24); of 28 June 2018, Andres (Insolvenz Heitkamp
   BauHolding) v Commission ([354]C-203/16 P, [355]EU:C:2018:505,
   paragraph [356]94); of 21 December 2016, Commission v World Duty Free
   Group and Others ([357]C-20/15 P and C-21/15 P, [358]EU:C:2016:981,
   paragraph [359]59); and of 29 March 2012, 3M Italia ([360]C-417/10,
   [361]EU:C:2012:184, paragraph [362]42).

   ( [363]48 ) Judgment of 21 December 2016, Commission v World Duty Free
   Group and Others ([364]C-20/15 P and C-21/15 P, [365]EU:C:2016:981,
   paragraph [366]58); see, to that effect, judgments of 29 March 2012, 3M
   Italia ([367]C-417/10, [368]EU:C:2012:184, paragraph [369]40); of
   8 September 2011, Paint Graphos ([370]C-78/08 to C-80/08,
   [371]EU:C:2011:550, paragraphs [372]64 and [373]65); and of 29 April
   2004, Netherlands v Commission ([374]C-159/01, [375]EU:C:2004:246,
   paragraphs [376]42 and [377]43).

   ( [378]49 ) Judgments of 18 July 2013, P ([379]C-6/12,
   [380]EU:C:2013:525, paragraph [381]22), and of 8 September 2011, Paint
   Graphos ([382]C-78/08 to C-80/08, [383]EU:C:2011:550, paragraph [384]65
   and the case-law cited).

   ( [385]50 ) See judgments of 26 April 2018, ANGED ([386]C-236/16
   and C-237/16, [387]EU:C:2018:291, paragraph [388]40 et seq.); of
   26 April 2018, ANGED ([389]C-234/16 and C-235/16, [390]EU:C:2018:281,
   paragraph [391]45 et seq.); and of 26 April 2018, ANGED ([392]C-233/16,
   [393]EU:C:2018:280, paragraph [394]52 et seq.), where this was
   acknowledged with regard to environmental and town and country planning
   reasons in connection with a tax on retail sales area.

   ( [395]51 ) See judgments of 21 December 2016, Commission v World Duty
   Free Group and Others ([396]C-20/15 P and C-21/15 P,
   [397]EU:C:2016:981, paragraph [398]53 et seq.); of 9 October 2014,
   Ministerio de Defensa and Navantia ([399]C-522/13, [400]EU:C:2014:2262,
   paragraph [401]23); of 29 March 2012, 3M Italia ([402]C-417/10,
   [403]EU:C:2012:184, paragraph [404]39); of 15 November 2011, Commission
   and Spain v Government of Gibraltar and United Kingdom ([405]C-106/09 P
   and C-107/09 P, [406]EU:C:2011:732, paragraph [407]73); and of
   8 November 2001, Adria-Wien Pipeline and Wietersdorfer & Peggauer
   Zementwerke ([408]C-143/99, [409]EU:C:2001:598, paragraph [410]35).

   ( [411]52 ) See, inter alia, judgment of 19 December 2018, A-Brauerei
   ([412]C-374/17, [413]EU:C:2018:1024, paragraph [414]36).

   ( [415]53 ) See my Opinion in Tesco-Global Áruházak ([416]C-323/18,
   [417]EU:C:2019:567, point [418]150).

   ( [419]54 ) See judgments of 21 December 2016, Commission v Aer Lingus
   and Ryanair Designated Activity ([420]C-164/15 P and C-165/15 P,
   [421]EU:C:2016:990, paragraph [422]51); of 21 December 2016, Commission
   v World Duty Free Group and Others ([423]C-20/15 P and C-21/15 P,
   [424]EU:C:2016:981, paragraph [425]54); of 21 December 2016, Commission
   v Hansestadt Lübeck ([426]C-524/14 P, [427]EU:C:2016:971,
   paragraphs [428]49 and [429]58); of 9 October 2014, Ministerio de
   Defensa and Navantia ([430]C-522/13, [431]EU:C:2014:2262,
   paragraph [432]35); of 18 July 2013, P ([433]C-6/12,
   [434]EU:C:2013:525, paragraph [435]19); of 29 March 2012, 3M Italia
   ([436]C-417/10, [437]EU:C:2012:184, paragraph [438]42); and of
   8 September 2011, Paint Graphos ([439]C-78/08 to C-80/08,
   [440]EU:C:2011:550, paragraph [441]49).

   ( [442]55 ) See judgments of 18 July 2013, P ([443]C-6/12,
   [444]EU:C:2013:525, paragraph [445]22), and of 8 September 2011, Paint
   Graphos ([446]C-78/08 to C-80/08, [447]EU:C:2011:550,
   paragraphs [448]65 and [449]69); see also to that effect, inter alia,
   judgments of 9 October 2014, Ministerio de Defensa and Navantia
   ([450]C-522/13, [451]EU:C:2014:2262, paragraphs [452]42 and [453]43);
   of 15 November 2011, Commission and Spain v Government of Gibraltar and
   United Kingdom ([454]C-106/09 P and C-107/09 P, [455]EU:C:2011:732,
   paragraph [456]145); of 8 November 2001, Adria-Wien Pipeline and
   Wietersdorfer & Peggauer Zementwerke ([457]C-143/99,
   [458]EU:C:2001:598, paragraph [459]42); and of 2 July 1974, Italy v
   Commission ([460]173/73, [461]EU:C:1974:71, paragraph [462]33).

   ( [463]56 ) Judgments of 26 April 2018, ANGED ([464]C-236/16
   and C-237/16, [465]EU:C:2018:291, paragraph [466]40 et seq.); of
   26 April 2018, ANGED ([467]C-234/16 and C-235/16, [468]EU:C:2018:281,
   paragraph [469]45 et seq.); and of 26 April 2018, ANGED ([470]C-233/16,
   [471]EU:C:2018:280, paragraph [472]52 et seq.).

   ( [473]57 ) Judgment of 21 December 2016, Commission v World Duty Free
   Group and Others ([474]C-20/15 P and C-21/15 P, [475]EU:C:2016:981,
   paragraphs [476]54, [477]67 and [478]74).

   ( [479]58 ) See also judgment of 19 December 2018, A-Brauerei
   ([480]C-374/17, [481]EU:C:2018:1024, paragraph [482]45); a contrary
   view is taken in the judgment of 26 April 2018, ANGED ([483]C-233/16,
   [484]EU:C:2018:280, paragraphs [485]52, [486]59 and [487]61); although
   the tax was based on the principle of taxation according to the ability
   to pay, the Court examined only the non-fiscal reasons of
   `environmental protection' and `town and country planning' expressly
   mentioned in the preamble.

   ( [488]59 ) Judgments of 28 June 2018, Andres (Insolvenz Heitkamp
   BauHolding) v Commission ([489]C-203/16 P, [490]EU:C:2018:505,
   paragraph [491]91); of 26 April 2018, ANGED ([492]C-233/16,
   [493]EU:C:2018:280, paragraph [494]47); of 26 April 2018, ANGED
   ([495]C-234/16 and C-235/16, [496]EU:C:2018:281, paragraph [497]40); of
   26 April 2018, ANGED ([498]C-236/16 and C-237/16, [499]EU:C:2018:291
   paragraph [500]35); and of 22 December 2008, British Aggregates v
   Commission ([501]C-487/06 P, [502]EU:C:2008:757, paragraph [503]89).

References

   1. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0001
   2. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0002
   3. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0003
   4. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0004
   5. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0005
   6. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0006
   7. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0007
   8. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0008
   9. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0009
  10. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0010
  11. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0011
  12. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0012
  13. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0013
  14. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0014
  15. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0015
  16. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0016
  17. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0017
  18. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0018
  19. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0019
  20. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0020
  21. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0021
  22. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0022
  23. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0023
  24. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0024
  25. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0025
  26. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0026
  27. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0027
  28. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0028
  29. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0029
  30. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0030
  31. file:///tmp/lynxXXXXdiG4b2/L85806-8781TMP.html#t-ECR_62019CC0596_EN_01-E0031
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