47However, granting the tax advantage in question in the main proceedings to persons who are not insured under the Netherlands social security system would amount to treating different situations in the same way, since insured persons under that system are entitled only in exceptional circumstances to tax credits in respect of social security. It is only in a situation where an insured person cannot set off reductions in contributions against contributions due that he can seek to obtain such tax credits. On the other hand, noninsured persons, such as the applicant in the main proceedings, would always automatically be entitled to a tax credit by virtue of the grant of reductions in contributions in respect of social security. As there is no obligation to pay contributions, such a person can never offset those reductions against social security contributions due.
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