83On that basis, Article 5(1) of the Directive establishes the principle that withholding taxes on profits distributed by a subsidiary established in one Member State to its parent company established in another Member State are prohibited. The temporary derogations for the German, Greek and Portuguese tax systems, announced in the fifth recital, are laid down in express terms in Article 5(2), (3) and (4) of the Directive. There is no similar provision establishing an express derogation for the United Kingdom tax system.
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