67In the second place, it must be held that, in the framework of the calculation of the taxable income of resident parent companies which hold shares in foreign subsidiaries, the prohibition on deducting losses such as those at issue in the main proceedings produces immediate effects. Accordingly, the fact that it is possible, subsequently, to obtain an exemption for capital gains realised on a disposal, assuming that a sufficient level of profit is achieved, does not constitute a consideration based on fiscal coherence which is capable of justifying a refusal to allow an immediate deduction in respect of losses incurred by parent companies which hold shares in foreign subsidiaries.
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